People v. Argawanon
REITERATIONFacts
The Antecedents: Appellants Alfredo Argawanon and Teddy Sericon, along with Ernie Lambujon, were accused of murder and theft. The information for theft alleged that on August 14, 1986, at around 4:20 PM, in Sitio Sumimbang, Barangay Bitoon, Daanbantayan, Cebu, Alfredo Argawanon unlawfully took a .38 caliber Smith and Wesson revolver from the dead body of Patrolman Aquiles Castro. The information for murder alleged that on the same date and time, the accused, conspiring and confederating, armed with two .45 caliber pistols, attacked, assaulted, and shot Patrolman Aquiles Castro twice at the back of the head with treachery and evident premeditation, causing his instantaneous death. Procedural History: While the cases were pending, Argawanon escaped and Sericon remained at large. Ernie Lambujon was tried separately and convicted of murder by the trial court, but was later acquitted by the Supreme Court. Argawanon and Sericon were arrested in 1989 and 1990, respectively. They pleaded not guilty. On January 14, 1992, the trial court rendered a joint decision acquitting Argawanon of theft but finding him and Teddy Sericon guilty of murder, sentencing them to reclusion perpetua and ordering them to indemnify the heirs of Aquiles Castro. Argawanon appealed. The Petition: Appellant Alfredo Argawanon appealed the trial court's decision finding him guilty of murder.
Issue(s)
Whether the guilt of appellant Alfredo Argawanon for the crime of murder was proven beyond reasonable doubt. Whether conspiracy to commit murder was sufficiently established. Whether the testimony of the prosecution witness, Jennies Castro, sufficiently established the guilt of the appellant.
Ruling
The judgment of conviction against Alfredo Argawanon is REVERSED, and he is ACQUITTED of the crime charged on the ground of reasonable doubt. The Court orders his immediate release from detention unless held for some other legal cause.
Ratio Decidendi
On the guilt of appellant Alfredo Argawanon for the crime of murder: The Court found merit in Argawanon's appeal. The trial court relied heavily on the testimony of Jennies Castro, the victim's brother. However, the Court noted that Jennies Castro's testimony, when examined closely, appeared to establish Argawanon's innocence rather than his guilt. Castro testified that after the victim was shot, Argawanon took the victim's service revolver and fired it into the air. When cross-examined, Castro confirmed that Argawanon did not aim the gun at his brother and that Argawanon fired the shot into the air. The Court stated that this act, while possibly imprudent, was susceptible to various interpretations and could not, by itself, be inculpatory, citing People vs. Alzaga. The Court emphasized that a conviction must rest on moral certainty of guilt, which was lacking here. On whether conspiracy to commit murder was sufficiently established: The record was found to be bereft of any evidence to establish conspiracy to kill the victim. The Court reiterated that criminal conspiracy must be founded on facts and established by clear and convincing evidence, citing People vs. Campos and People vs. Laurio. The prosecution failed to present such evidence to link Argawanon to the conspiracy to commit murder. On whether the testimony of the prosecution witness, Jennies Castro, sufficiently established the guilt of the appellant: The Court expressed serious dubiety regarding the credibility of Jennies Castro's testimony. The Court pointed out inconsistencies and implausibilities in his account, such as his failure to immediately inform the victim's wife and other relatives after witnessing the shooting, and his ability to escape and hide when the alleged assailants were armed with .45 caliber pistols. The Court also referred to its previous decision in People vs. Argawanon (215 SCRA 652) where it had expressed disbelief in Jennies Castro's testimony. The Court concluded that a conviction cannot rest on less than a moral certainty of guilt, which was not met by Castro's testimony, citing People vs. Castro.
Main Doctrine
The testimony of a witness, if it establishes the accused's innocence rather than guilt, must be given due weight. Furthermore, criminal conspiracy must be established by clear and convincing evidence, and mere presence at the scene of the crime or an imprudent act does not automatically establish guilt or conspiracy.