Aguirre v. People
REITERATIONFacts
The Antecedents: Petitioner Liwanag Aguirre, an Acting Deputy Sheriff for the National Labor Relations Commission (NLRC), was accused of direct bribery under Article 210 of the Revised Penal Code. The charge stemmed from an alleged demand and receipt of P50.00 from Hermogenes Hanginon, an employee of Guardsman Security Agency. This payment was purportedly made to delay the immediate implementation of a Writ of Execution issued by the NLRC against the agency. Procedural History: Following the filing of an Information, petitioner pleaded not guilty. The Sandiganbayan (First Division) proceeded with the trial and, based on the evidence presented, convicted petitioner of direct bribery. The Sandiganbayan considered the mitigating circumstance of voluntary surrender but found no aggravating circumstances. Petitioner was sentenced to two months and one day of arresto mayor, with accessories, a fine of P50.00, subsidiary imprisonment in case of insolvency, and indemnification of P50.00 to the victim, along with costs. The Petition: Petitioner seeks review of the Sandiganbayan's decision, arguing that the evidence presented failed to prove his guilt beyond a reasonable doubt. The core of his petition is that the Sandiganbayan erred in relying solely on the uncorroborated testimony of the lone prosecution witness, Hermogenes Hanginon. The petition contends that this uncorroborated testimony is insufficient to overcome the constitutional presumption of innocence.
Issue(s)
Whether the uncorroborated testimony of a single witness is sufficient to prove guilt beyond reasonable doubt in a criminal case. Whether the evidence presented sufficiently established the guilt of the petitioner for the crime of direct bribery.
Ruling
The judgment of conviction of the respondent Sandiganbayan is REVERSED. Liwanag Aguirre is ACQUITTED of the crime charged.
Ratio Decidendi
On the sufficiency of uncorroborated testimony: While it is settled that the testimony of only one witness may be sufficient to support a conviction if it convinces the court beyond reasonable doubt, this Court must ascertain that no person is made to answer for a crime without proof of guilt beyond reasonable doubt. The constitutional presumption of innocence imposes a duty to ensure that convictions are based on evidence that produces conviction in an unprejudiced mind. In this case, the conviction was anchored upon the uncorroborated testimony of a single prosecution witness. The Sandiganbayan relied on the witness's testimony, finding it "sufficiently impeccable and carries the ring of truth" and noting the forthright and spontaneous manner of its disclosure, as well as the lack of a compelling motive for the witness to perjure himself. However, the Court found aspects of the testimony that did not inspire belief, such as the alleged demand for a bribe from a mere employee without authority and without money, and the doubtful voluntary parting of personal funds without expectation of refund. Furthermore, the absence of an entrapment, which would have been a logical procedure given the circumstances, raised further doubts. On the evidence establishing guilt beyond reasonable doubt: After careful examination of the decision and evidence, nagging doubt remained as to whether the testimony of the sole witness proved the petitioner's guilt beyond reasonable doubt. The Court observed that "The scales of justice must hang equal and, in fact should be tipped in favor of the accused because of the constitutional presumption of innocence." In the absence of evidence establishing the guilt of the petitioner beyond reasonable doubt, the judgment of conviction must yield to the constitutional presumption of innocence.
Main Doctrine
The conviction of an accused based solely on the uncorroborated testimony of a single witness must be scrutinized with utmost care, and if nagging doubts remain regarding the guilt of the petitioner, the constitutional presumption of innocence must prevail, leading to acquittal.