In Capistrano Daayata, Dexter Salisi, and Bregido Malacat, Jr. v. People of the Philippines, the Supreme Court acquitted the petitioners of frustrated murder, emphasizing that the prosecution failed to prove their guilt beyond reasonable doubt. The Court highlighted inconsistencies in the prosecution’s evidence, including the victim’s admission of a different cause of injury and the lack of corroboration regarding the use of weapons. This ruling underscores the importance of establishing moral certainty in criminal cases and ensures that the accused benefits from the presumption of innocence when reasonable doubt persists.

From Basketball Court to Courtroom: When a Sporting Quarrel Leads to Doubt

The case originated from an altercation that followed a basketball game. Rolando Bahian accused Capistrano Daayata, Dexter Salisi, and Bregido Malacat, Jr. of attacking him the next day, resulting in a severe head injury. The prosecution argued that the petitioners conspired to commit frustrated murder, presenting testimonies from Bahian, a Kagawad, and a Barangay Captain, along with medical records. The defense, however, presented a different version of events, claiming that Bahian sustained the injury by accidentally hitting his head on the pavement during a scuffle he initiated. This discrepancy in narratives became central to the Supreme Court’s assessment of the evidence.

The Supreme Court emphasized that a Rule 45 petition generally confines itself to questions of law. However, recognized exceptions exist, allowing the Court to overturn factual findings when there is a misapprehension of facts. Proof beyond reasonable doubt, as stated in Rule 133, Section 2 of the Revised Rules on Evidence, requires moral certainty. The prosecution must establish guilt to a degree that produces conviction in an unprejudiced mind. The Court noted several critical inconsistencies that undermined the prosecution’s case.

Firstly, the exact location of the altercation was a point of contention. While the prosecution presented it as a sudden ambush, the defense argued that Bahian and his companion went to the vicinity of Vicente’s house, where the confrontation occurred. This suggests a premeditated challenge rather than an unprovoked attack. Secondly, the medical evidence contradicted the claim of a prolonged, relentless assault. Bahian’s medical certificate showed only one injury on his forehead, raising doubts about the severity and nature of the alleged beating. Physical evidence, as the Court noted, “speaks more eloquently than a hundred witnesses,” and the lack of widespread injuries cast doubt on the prosecution’s version of events.

Crucially, Bahian himself admitted that his head injury was caused by hitting the edge of the concrete pavement, initially telling this to Dr. Mata. During cross-examination, Bahian explained that he lied to receive treatment, but the Court found this explanation unconvincing. The defense highlighted the coincidence between Bahian’s initial statement and their version of events, suggesting a potential truth in Bahian’s initial account. Furthermore, multiple witnesses, including Barangay Captain Yañez, contradicted the prosecution’s claim that the petitioners wielded weapons. Barangay Captain Yañez, a prosecution witness, testified that he did not see anyone holding a bolo, steel pipe, or gun.

These inconsistencies, combined with the lack of corroborating evidence, led the Supreme Court to conclude that the prosecution failed to establish moral certainty. The Court reiterated the principle that an accused is presumed innocent until proven guilty, and this presumption can only be overcome by proof beyond reasonable doubt. In this case, the prosecution’s narrative was undermined by conflicting testimonies and a lack of physical evidence, thus, the Court emphasized that the conviction of the accused must rest on the strength of the prosecution, not on the weakness of the defense.

The Court addressed the narrative of vindictiveness portrayed by the prosecution, highlighting Bahian’s initial threat to “get even” with Salisi. This suggested that Bahian himself initiated further conflict. The confluence of Bahian’s admissions, the limited physical injuries, and the contradictory testimonies raised substantial doubts about the petitioners’ guilt. As a result, the Supreme Court reversed the Court of Appeals’ decision and acquitted Capistrano Daayata, Dexter Salisi, and Bregido Malacat, Jr.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution presented enough evidence to prove beyond reasonable doubt that the petitioners were guilty of frustrated murder. The Supreme Court found that the prosecution’s evidence was inconsistent and insufficient, leading to the acquittal of the accused.
What is proof beyond reasonable doubt?	Proof beyond reasonable doubt is the standard of evidence required to convict a person in a criminal case. It means that the evidence presented must be so compelling that there is no reasonable doubt in the mind of an unprejudiced person that the accused committed the crime.
Why did the Supreme Court acquit the petitioners?	The Supreme Court acquitted the petitioners due to inconsistencies in the prosecution’s evidence. These included the victim’s initial statement about how he sustained his injury, the lack of corroboration for the use of weapons, and the limited physical injuries sustained relative to the alleged assault.
What role did the victim’s testimony play in the decision?	The victim’s testimony was critical, particularly his initial admission that he injured himself by hitting his head on the pavement. This admission, though later retracted, cast significant doubt on the prosecution’s claim that the petitioners intentionally inflicted the injury.
How did the lack of physical evidence affect the case?	The limited physical evidence, specifically the single injury on the victim’s forehead, contradicted the prosecution’s claim of a prolonged and relentless assault. This discrepancy undermined the credibility of the prosecution’s narrative.
What is the significance of the presumption of innocence?	The presumption of innocence is a fundamental right in criminal law, stating that a person accused of a crime is presumed innocent until proven guilty. The prosecution bears the burden of proving guilt beyond a reasonable doubt, and any failure to do so results in acquittal.
What was the impact of Barangay Captain Yañez’s testimony?	Barangay Captain Yañez’s testimony was significant because, as a prosecution witness, he contradicted the claim that the petitioners wielded weapons. His statement that he did not see anyone with a bolo, steel pipe, or gun weakened the prosecution’s case.
What does this case highlight about the burden of proof in criminal cases?	This case highlights that the prosecution must rely on the strength of its evidence, not the weakness of the defense. The prosecution must present a coherent and credible narrative that establishes guilt beyond a reasonable doubt, failing which the accused must be acquitted.

This case underscores the judiciary’s commitment to upholding the principles of reasonable doubt and the presumption of innocence. The decision serves as a reminder that convictions must be based on solid, credible evidence, and inconsistencies can undermine the prosecution’s case leading to acquittal.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: CAPISTRANO DAAYATA, ET AL. VS. PEOPLE, G.R. No. 205745, March 08, 2017