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PEOPLE v. SABAS RAQUEL

FACTS:

The accused-appellants, Sabas Raquel, Valeriano Raquel, and Amado Ponce, were found guilty by the lower court for the crime of robbery with homicide. They were sentenced to reclusion perpetua and were ordered to pay the heirs of Agapito Gambalan, Jr. an indemnity for his death and the value of the stolen revolver. The crime was allegedly committed on July 4, 1986 in Barangay Osias of the Municipality of Kabacan. Accused Amado Ponce escaped from jail before he could testify. The prosecution relied on the testimony of Juliet Gambalan, the lone eyewitness, who was not able to positively identify the assailants of her husband. The appellants pleaded for their absolution. The appellate court found that the prosecution failed to establish the real identities of the perpetrators and the participation of the appellants in the crime charged.

ISSUES:

  1. Did the trial court err in convicting accused Sabas Raquel and Valeriano Raquel of the crime of robbery with homicide, despite the absence of evidence positively implicating them as the perpetrators of the crime?

RULING:

The Supreme Court found the submission of the defense to be meritorious. After a careful review and objective appraisal of the evidence, it was concluded that the prosecution failed to establish beyond reasonable doubt the real identities of the perpetrators of, much less the participation of herein appellants in, the crime charged. The primary and sole eyewitness did not positively identify the accused as the assailants, and the corroborating witness did not witness who specifically shot the victim.

Moreover, the identification of the appellants as the culprits was mainly based on an extrajudicial statement of a co-accused, Amado Ponce, who had escaped custody and was thus unavailable for cross-examination. Such statements are considered hearsay if not expressed in open court where the accused have the opportunity to cross-examine the declarant. Consequently, on the grounds of reasonable doubt, the judgment was reversed, and the accused-appellants Sabas Raquel and Valeriano Raquel were acquitted of the offense charged.

PRINCIPLES:

  1. Presumption of Innocence - Every accused is presumed innocent until proven guilty beyond reasonable doubt.

  2. Extrajudicial Statements - Extrajudicial statements implicating co-accused cannot be used against them unless repeated in open court where cross-examination is possible.

  3. Hearsay Rule - Statements that have not been subject to cross-examination are generally inadmissible due to the hearsay rule.

  4. Right to Counsel - During custodial interrogation, an accused must be informed of their rights, including the right to counsel. If the right to counsel is not observed, any statement made during such a situation is inadmissible as evidence.

  5. Proof Beyond Reasonable Doubt - Conviction must be based on a moral certainty of guilt, where all reasonable doubts are resolved in favor of the accused.

  6. Res Inter Alios Acta Rule - A person's rights cannot be prejudiced by the acts, declarations, or omissions of another which are extrajudicial. Statements are admissible only against the person who makes them.

  7. Identification of Accused - Identification by witnesses must be clear and positive to suffice as proof beyond reasonable doubt in criminal cases.

  8. Weakness of the Defense Does Not Strengthen the Prosecution's Case - The prosecution must rely solely on the strength of its own evidence, not on the weakness of the defense.

  9. Constitutional Rights During Interrogation - Violations of constitutional rights during interrogation render any resultant confessions or admissions therein inadmissible.