People v. Aquino
REITERATIONFacts
The Antecedents: Pedro Casimina, his son Romeo Casimina, and Nazarito Aquino were accused of murder for allegedly shooting Benigno Pascua in Barrio Bangilan, Kabacan, Cotabato. The prosecution alleged that the killing was committed with treachery and evident premeditation. Procedural History: The Court of First Instance of Cotabato found all three accused guilty of murder and sentenced them to reclusion perpetua. They appealed the decision. However, Nazarito Aquino was allowed to withdraw his appeal. This decision concerns only Pedro and Romeo Casimina. The Petition: The appellants impugned the trial court's reliance on the testimony of the victim's eight-year-old son, Benigno Pascua, Jr., citing incompetency and unreliability. They also questioned the credibility of other prosecution witnesses, Pacifico Narvas and Romulo Pascua, and the appreciation of motive by the trial court.
Issue(s)
Whether the eight-year-old child witness, Benigno Pascua, Jr., was competent and reliable under Rule 130 of the Rules of Court. Whether the identification of the appellants by the prosecution witnesses was credible enough to constitute proof beyond reasonable doubt.
Ruling
The Court reversed the conviction of Pedro and Romeo Casimina, finding that their guilt was not proven beyond reasonable doubt. The Court acquitted them, with costs de oficio.
Ratio Decidendi
On Issue 1: The Court ruled that the child witness, Benigno Pascua, Jr., lacked the required degree of intelligence and reliability. Under Rule 130, Section 19(c), competency involves the capacity to receive and relate facts truly, which Benigno Jr. failed to demonstrate as he could not identify his municipality, school details, or even the month of his father's death. The Court found that he had been coached by the Chief of Police, who admitted to telling the boy to point to the accused during a confrontation at the police station. Furthermore, Benigno Jr. denied signing the sworn statement that formed the basis of his testimony, and his age was inconsistently reported as ten in the statement but eight in court. These inconsistencies, combined with the clear evidence of coaching, rendered his testimony regarding the identification of the shooters entirely untrustworthy. On Issue 2: The identification provided by the other witnesses, Pacifico Narvas and Romulo Pascua, was deemed physically improbable and contrary to human experience. They claimed to recognize the accused from eighty meters away while the accused were running away with their backs turned, despite the presence of tall, leafy cornstalks that would have obstructed their view. The Court noted that Narvas' claim of climbing a tree during the shooting to observe the assailants was inconsistent with typical human behavior in moments of extreme danger, where one would normally seek cover rather than expose themselves. The witnesses also failed to reveal the identities of the culprits to the police on the night of the incident, waiting twelve days to execute their sworn statements. Since evidence must be credible in itself to be believed, and the prosecution's identification was weak and uncorroborated, the motive alone—even if strong—was insufficient to overcome the presumption of innocence.
Main Doctrine
The prosecution failed to prove the guilt of the accused beyond reasonable doubt due to the unreliable testimony of the child witness and the lack of credible corroborating evidence. The weakness of the defense does not relieve the prosecution of its burden of proof.