People v. Ang-Nguho
REITERATIONFacts
The Antecedents: The accused-appellant, Abubakar Ang-Nguho, along with nine others, was charged with murder for allegedly conspiring and confederating to assault and shoot Pianang Salih with firearms on May 1, 1995, in Amaloy, Tipo-Tipo, Basilan, causing her death. The victim's death certificate stated the cause as "Cardio-pulmonary arrest due to Hypovolemic shock secondary to Gun shot wound penetrating the abdomen." Procedural History: The Regional Trial Court (RTC), Branch 2, of Isabela, Basilan, found the accused-appellant guilty of murder with the aggravating circumstances of treachery and band, sentencing him to death. The RTC relied on the eyewitness account of Sattar Sahi and the dying declaration of the victim, Pianang Salih, to her brother, Hadji Muin Salih. The Petition: The accused-appellant appealed the RTC decision, contending that the RTC erred in giving undue credence to the prosecution's evidence and in imposing the death penalty despite the presence of reasonable doubt.
Issue(s)
Whether the RTC erred in giving credence to the prosecution's evidence. Whether the RTC erred in imposing the death penalty despite reasonable doubt.
Ruling
The Supreme Court reversed the decision of the Regional Trial Court, acquitting the accused-appellant Abubakar Ang-Nguho on the ground of reasonable doubt. The Court ordered his immediate release from custody unless lawfully held for another case.
Ratio Decidendi
On the credibility of prosecution evidence: The Supreme Court found the eyewitness account of Sattar Sahi improbable and unworthy of credence. Sahi's testimony contained inconsistencies regarding the number of assailants and their firearms, and his ability to identify them from a distance of 20 meters amidst a commotion was questioned. The Court also noted the delay in Sahi's sworn statement. Furthermore, the Court doubted the veracity of the dying declaration of Pianang Salih, citing conflicting testimonies from Sattar Sahi and Dr. Pilardo Perez, who stated the victim was unconscious and unable to talk when attended to at the hospital. The inconsistency between the number of assailants mentioned in the affidavits and information (ten) versus the number testified to by Sahi (seven) further weakened the prosecution's case. The delay in the execution of sworn statements by Hadji Muin Salih and Sattar Sahi, more than two weeks after the incident, was also considered. On the imposition of the death penalty and reasonable doubt: The Court held that the prosecution failed to establish the guilt of the accused-appellant beyond reasonable doubt. The inconsistencies and doubts surrounding the eyewitness testimony and the dying declaration created a lack of moral certainty required for conviction. The Court emphasized that a strong suspicion or probability of guilt is insufficient. Regarding the accused-appellant's alibi, the Court noted that it did not need to be inquired into because the prosecution's evidence did not meet the required standard of moral certainty. Therefore, the RTC's imposition of the death penalty was erroneous, and acquittal was the only recourse.
Main Doctrine
The prosecution failed to establish the guilt of the accused beyond reasonable doubt due to inconsistencies in eyewitness testimony, doubts regarding the dying declaration, and the delay in the execution of sworn statements. The inconsistencies regarding the number of assailants and the weapons used, coupled with the victim's alleged inability to speak after the incident, created reasonable doubt, necessitating acquittal.