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PEOPLE v. SERVANDO SATURNO

FACTS:

The case involves an appeal by accused Servando Saturno, Abraham Rodriguez, and Benigno Andres from the decision of the Regional Trial Court (RTC) finding them guilty beyond reasonable doubt of multiple murder. The information filed by the provincial prosecutor charged the accused with conspiring, confederating, and aiding one another to kill four individuals in Barangay Agupalo Este, Municipality of Lupao, Nueva Ecija. The trial court arraigned the accused separately, and they all pleaded not guilty.

The facts of the case are as follows:

On June 23, 1989, Rodelito Valdez, Benigno Andres, Jose Lopez Jr., Protacio Pasalusdos, Florencio Bulatao, and Matias Andres were having a drinking spree at Rodelito Valdez's house. Benigno Andres left around lunchtime to supposedly go to Muñoz. Lucila Valdez, Rodelito's wife, asked him to buy her a kilo of pinapaitan and oil. Later that afternoon, the drinking companions fell asleep.

At around 5:30 PM, Lucila heard a tricycle park near their house, and the last passenger to alight was Benigno Andres. Thinking he came to deliver the pinapaitan, Lucila went to meet him downstairs. However, a man wearing a light brown jacket and fatigue cap appeared and asked for her husband. Lucila informed him that Rodelito was drunk and couldn't be awakened. Despite this, the man went straight to their house, and Lucila followed. The man woke up Rodelito and demanded his gun. When Rodelito said he didn't have one, the man shot him. Lucila cried for help, but the man ordered her to be quiet and stay in the corner of the room.

The man's companions brought Jose Lopez Jr. and Protacio Pasalusdos to the bedroom and hog-tied them. Florencio Bulatao arrived later and was also hog-tied. Lucila saw that the hog-tied victims were taken separately downstairs, and she heard gunshots each time a body was brought down. She tried to open her eyes again, and she saw that the man in the light brown jacket was still there, pointing his gun at her. She closed her eyes and heard two gunshots. When she looked again, the man was gone, and she realized the shots were aimed at her husband.

After the incident, Lucila and others were interrogated by the police authorities. Lucila repeatedly stated that she could not identify the assailants. Empty shells and deformed slugs were recovered from the cadavers. Accused Servando Saturno was apprehended and questioned, and he was asked to return to the police camp the following day. Lucila went to the camp the next day, where she was asked to identify Saturno. Pictures were taken showing Lucila pointing at Saturno, his gun, light brown jacket, and fatigue cap, which were later identified as Saturno's belongings.

The other accused were arrested later, and they executed affidavits admitting their participation in the crime and implicating Delfin Gregorio as the one who paid them to kill Rodelito Valdez. All the accused denied the charges against them. Saturno claimed he was sick and at home during the relevant period, and that he was coerced into confessing by being maltreated and tortured. He also claimed that the letters he wrote asking for his belongings were forced and that his gun was never subjected to ballistic examination or paraffin test. Lt. Peter Torres testified that the gun used in the killing was with him prior to June 22, 1989, and he was ordered to surrender it by Sgt. Pillonar.

Delfin Gregorio testified that he accompanied Lucila Valdez to the police headquarters and that she was asked to point at Saturno and his tricycle. He also claimed that he was maltreated and forced to confess.

ISSUES:

  1. Whether the prosecution was able to prove the guilt of the appellants beyond reasonable doubt.

  2. Whether the defense of alibi raised by the appellants is sufficient to overcome the positive identification made by the witness.

  3. Whether the prosecution was able to prove the guilt of the accused beyond reasonable doubt.

  4. Whether the identification of the accused as the perpetrators of the crime is reliable.

  5. Whether or not the prosecution was able to prove the guilt of accused-appellants Servando Saturno, Abraham Rodriguez, and Benigno Andres beyond reasonable doubt.

  6. Whether or not there are lawful grounds for the continued detention of accused-appellants.

RULING:

  1. The appeal is meritorious. The court held that the prosecution failed to prove the guilt of the appellants beyond reasonable doubt. The court also found that the defense of alibi raised by the appellants is weak and cannot prevail over the positive identification made by the witness.

  2. The Court ruled that the prosecution failed to prove the guilt of the accused beyond reasonable doubt. While the prosecution was able to establish the fact of the killing, it failed to prove that the accused perpetrated the crime. The evidence presented by the prosecution, such as the bloodstained jacket and slugs, were not properly identified and offered in evidence. Furthermore, the identification of the accused as the assailants was not convincing. Thus, the constitutional presumption of innocence favors the accused, resulting in their acquittal.

  3. The Court also found the identification of the accused as the perpetrators of the crime to be unreliable. Witness testimony was inconsistent and lacked specificity. There were also inconsistencies in the testimony of the witness regarding her disposition during the incident. The identification of the accused by the witness could not be considered positive and credible. Hence, the Court gave weight to the defense of alibi and denial presented by the accused, which gained strength in light of the unreliable identification.

  4. The court acquits accused-appellants Servando Saturno, Abraham Rodriguez, and Benigno Andres due to the failure of the prosecution to prove their guilt beyond reasonable doubt. The Director of Corrections is ordered to immediately release the accused-appellants unless they are lawfully held for another cause. The Court should also be informed of their release within ten days from notice. No costs are imposed.

PRINCIPLES:

  • The guilt of an accused must be proved beyond reasonable doubt.

  • Positive identification prevails over denial and alibi.

  • The task of the prosecution in a criminal case is to prove beyond reasonable doubt that a crime was committed and that the accused is responsible for it.

  • The identification of the accused as the perpetrator of the crime must be reliable and based on credible evidence.

  • The constitutional presumption of innocence in favor of the accused prevails when the prosecution fails to prove guilt beyond reasonable doubt.

  • Alibi, though considered a weak defense, may be sufficient to acquit the accused when supported by evidence and in light of the unreliable identification of the perpetrators.

  • When the evidence in a criminal case is evenly balanced and capable of two or more explanations, one consistent with the innocence of the accused and the other consistent with guilt, the constitutional presumption of innocence tilts the scales in favor of the accused.

  • The prosecution has the burden of proving the guilt of the accused beyond reasonable doubt.

  • The accused should be acquitted if the prosecution fails to meet the required standard of proof.

  • The Director of Corrections is responsible for the release of the accused upon acquittal, unless there are lawful grounds for their continued detention.