G.R. No. 110991 -92 February 24, 1995
People of the Philippines vs. Melchor dela Iglesia

FACTS

Accused-appellant Melchor dela Iglesia was charged with two counts of murder for the killing of Manuel P. Baquiran and his son Johnson Baquiran on November 2, 1990, in Sto. Nino, Cagayan. The prosecution’s case relied primarily on the testimonies of Bartolome Baquiran and Rosalinda Baquiran. Bartolome testified that on the night of the incident, armed men, including the accused-appellant whom he recognized, surrounded their hut, ordered them out, and after a conversation with their relative Nelson Panaga, took Manuel and Johnson away. Their bodies were found days later with multiple gunshot wounds. Rosalinda testified about a land dispute between her husband and the accused-appellant as the motive. The defense presented alibi, with witnesses including Nelson Panaga, Mateo Relos, and Vioquelin Villena testifying that the accused-appellant was on guard duty at an Iglesia ni Kristo chapel the entire night of the crime. Nelson Panaga, who was present during the abduction, initially stated in an unsworn affidavit that he did not recognize the armed men but later testified for the defense. The Regional Trial Court convicted the accused-appellant of two counts of murder and sentenced him to two life imprisonments.

ISSUE

The main issues were whether the trial court erred in not appreciating the testimony of defense witness Nelson Panaga, in holding that Panaga was the accused-appellant’s brother-in-law, and in convicting the accused-appellant based effectively on circumstantial evidence.

RULING

The Supreme Court REVERSED the trial court’s judgment and ACQUITTED the accused-appellant based on reasonable doubt. The Court found that the testimony of prosecution eyewitness Bartolome Baquiran was inconsistent and unreliable, as he gave conflicting statements about recognizing the accused-appellant and the events of the abduction. The Court noted that Nelson Panaga’s testimony, which was consistent with his earlier unsworn statement that he did not recognize the abductors, cast doubt on Bartolome’s version. The Court also found the trial court’s reference to Panaga as the accused-appellant’s brother-in-law to be an unfounded assumption not supported by the records. The prosecution’s evidence, which the Supreme Court characterized as a collection of weak circumstantial evidence, failed to form an unbroken chain leading to the accused-appellant’s guilt beyond reasonable doubt. While the accused-appellant’s alibi was weak, the prosecution’s evidence was weaker and insufficient to overcome the constitutional presumption of innocence.