G.R. No. L-873; September 18, 1947
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JUAN CAUILAN and JOSE QUILANG, defendants-appellants.

FACTS

The defendants-appellants, Juan Cauilan and Jose Quilang, were convicted of murder by the Court of First Instance of Cagayan and sentenced to reclusion perpetua. The conviction was based primarily on the testimony of a single eyewitness, Jose Dammay, the son of the deceased Vicente Dammay. Jose Dammay testified that on the night of April 28, 1945, in barrio Callao, Peñablanca, Cagayan, the two appellants came to their house and called for his father. He and his father followed the appellants. Upon reaching a riverbank, appellant Cauilan ordered Jose to go to Damian Bacud’s place. Instead, Jose hid among guava groves and from there allegedly saw Cauilan stab his father under the right armpit and Quilang bolo the back of his father’s head, resulting in his death that same night. However, on cross-examination, Jose gave a contradictory account, stating that he obeyed the order, went to Bacud’s place, and upon returning found his father already dead and the appellants about to leave, meaning he did not actually witness the killing. This testimony was also inconsistent with his sworn statement during the preliminary investigation, where he attributed the crime to the appellants only because they were the ones who took his father away that night, not because he saw them commit the act. Furthermore, when Jose and his mother found the body and reported it to Municipal Councilor Rufo Apattad, Jose did not tell Apattad that he saw the killing, only that the appellants had taken his father who was later found dead. The defense presented evidence that the appellants, who were guerrillas, had called the deceased by order of a sergeant to supply food to the guerrillas. They also presented an alternative theory that the deceased might have been killed by Japanese forces during a raid where Japanese rounded up and killed male persons in the barrio, following a guerrilla raid on Japanese food stores.

ISSUE

Whether the guilt of the appellants for the crime of murder has been proven beyond reasonable doubt based on the sole, contradictory, and inconsistent testimony of the principal witness, Jose Dammay.

RULING

The Supreme Court REVERSED the judgment of the Court of First Instance and ACQUITTED the appellants. The Court ruled that while the testimony of a single witness can be sufficient for conviction if persuasive, it cannot sustain a conviction when it is self-contradictory and inconsistent with the witness’s own prior statements. The testimony of Jose Dammay was found to be unreliable due to material contradictions between his court testimony and his cross-examination, and between his court testimony and his sworn statement during the preliminary investigation. The Court noted there was no evidence of motive for the appellants to kill the deceased, as they were all guerrilla companions, and there was no proof the deceased was a Japanese spy. The defense’s alternative explanation for the death, involving possible Japanese retaliation, was considered plausible. Therefore, the prosecution failed to prove the appellants’ guilt beyond reasonable doubt.