The Supreme Court, in Ambagan v. People, ruled that a mayor could not be held criminally liable as a principal by inducement for homicide due to reasonable doubt. The prosecution failed to convincingly prove that the mayor’s words directly led to the unlawful killings; inconsistencies in witness testimonies and alternative interpretations of events created doubt about the mayor’s intent and influence.

Did a Mayor’s Angry Words Directly Cause a Deadly Shootout?

This case revolves around Albert G. Ambagan, Jr., then the municipal mayor of Amadeo, Cavite, who was charged with two counts of homicide for the deaths of SPO2 Reynaldo Santos and Domingo Bawalan. The prosecution argued that Ambagan induced the killings by uttering the phrase “Sige, yan pala ang gusto mo. Mga kasama banatan na ninyo yan” (“Okay, that’s what you want. Companions, shoot them now”), which allegedly incited his bodyguards to open fire on the victims. The Sandiganbayan initially convicted Ambagan as a principal by inducement, leading to this appeal before the Supreme Court.

The central legal question is whether Ambagan’s statement, if indeed made, was the determining cause of the killings, thereby establishing his criminal liability as a principal by inducement. For a conviction as a principal by inducement, it must be proven that the inducement was made with the intention of procuring the commission of the crime and that such inducement was the direct cause of the act. The Supreme Court scrutinized the evidence, particularly the testimonies of key witnesses, to determine if these elements were sufficiently established beyond reasonable doubt.

The Court emphasized the importance of credible evidence and the prosecution’s burden to prove guilt beyond a reasonable doubt. The Court highlighted inconsistencies in the testimonies of the prosecution’s key witnesses, Victor J. Patam and Ronnel Bawalan. Patam, who was close to Ambagan during the altercation, did not corroborate Bawalan’s claim that Ambagan uttered the inciting phrase. Only Ronnel Bawalan testified that petitioner uttered “Sige, yan pala ang gusto mo. Mga kasama banatan na ninyo yan” just before the shooting.

“It is a cardinal principle in criminal law that the prosecution has the burden of proving the guilt of the accused beyond reasonable doubt. It is the primordial duty of the prosecution to present its side with clarity and persuasion, so that conviction becomes the only logical and inevitable conclusion, with moral certainty.”

The Supreme Court noted several reasons why Ronnel Bawalan’s testimony was not entirely credible. Bawalan claimed to have witnessed the entire shootout without blinking, yet he could not account for Ambagan’s location during the actual shooting. Moreover, the Court found it illogical that Ambagan would order his men to fire if he himself was in the line of fire. Patam’s testimony, in contrast, suggested that Ambagan wanted to check on his men after the shooting began, which is inconsistent with the idea that he initiated the violence. The Supreme Court also found it questionable that Ambagan did not draw his own weapon if he intended to start a shootout.

In evaluating the credibility of a witness, the Court noted that:

“So, too, this Court is not bound by the findings of the Sandiganbayan should it discover that the testimonies of the prosecution witnesses are marred with inconsistencies that are neither collateral nor trivial, but are material and substantial in matters determinative of petitioner’s guilt beyond reasonable doubt.”

The Supreme Court highlighted inconsistencies in Ronnel Bawalan’s statements regarding the casualties of the shootout. Initially, he claimed to have personally witnessed the deaths of Leandro Causaren and Edrelin Jamon, but later admitted that he only learned about their deaths from others. He also claimed that only Santos was armed, but gunpowder tests showed Domingo Bawalan was also armed. These contradictions, the Court reasoned, significantly undermined Bawalan’s credibility as a witness. Such detail is substantial because it tends to establish the probability or improbability of Santos starting the gunfight, as earlier discussed.

Moreover, the Court considered Bawalan’s potential bias due to his relationship with the victims. This bias, coupled with the inconsistencies in his testimony, led the Court to view his version of events with skepticism. The Court ultimately concluded that the prosecution’s evidence did not meet the standard of moral certainty required for a conviction. The scant evidence for the prosecution casts serious doubts as to the guilt of petitioner as principal by inducement. It was not convincingly established, beyond reasonable doubt, that petitioner indeed ordered his men to open fire at Santos and Domingo Bawalan.

Ultimately, the Supreme Court acquitted Ambagan, emphasizing that the evidence did not establish beyond a reasonable doubt that his words were the direct and determining cause of the killings. This decision underscores the high burden of proof required to establish criminal liability, especially in cases involving inducement. While the conviction of Michael T. Malabanan, Celestino “Ely” B. Garcia, and Roger V. Causaren for homicide as principals by direct participation was affirmed, the Court found insufficient evidence to link Ambagan directly to their actions.

FAQs

What was the key issue in this case?	The key issue was whether Albert Ambagan Jr., as mayor, could be held criminally liable as a principal by inducement for the deaths of Reynaldo Santos and Domingo Bawalan. The prosecution argued his words led to the killings, but the court examined if this was proven beyond a reasonable doubt.
What does “principal by inducement” mean?	A principal by inducement is someone who, with the intention of causing a crime, directly influences another to commit it. This requires proving that the inducement was intended to cause the crime and was the determining factor in its commission.
Why was Ambagan acquitted?	Ambagan was acquitted due to reasonable doubt. The Supreme Court found significant inconsistencies in the testimonies of key prosecution witnesses, making it unclear whether his words directly caused the shootings.
What inconsistencies were found in the testimonies?	Key inconsistencies included whether Ambagan made the inciting statement, his location during the shooting, and details about the casualties. These discrepancies undermined the credibility of the prosecution’s witnesses.
What role did Patam’s testimony play in the decision?	Patam, a witness close to Ambagan, did not corroborate the claim that Ambagan made the inciting statement. His testimony that Ambagan shouted invectives was not explicit order and raised further doubt.
How did the court view Bawalan’s testimony?	The court viewed Bawalan’s testimony with skepticism due to inconsistencies and potential bias. His inability to accurately describe key events and his relationship to the victims cast doubt on his version of the facts.
What is the standard of proof in criminal cases?	In criminal cases, the prosecution must prove the defendant’s guilt beyond a reasonable doubt. This means the evidence must be so compelling that there is no logical reason to doubt the defendant’s guilt.
What is the effect of a negative paraffin test result?	A negative paraffin test result indicates the person tested did not discharge a firearm.
Were any other individuals convicted in this case?	Yes, Michael T. Malabanan, Celestino “Ely” B. Garcia, and Roger V. Causaren were convicted of homicide as principals by direct participation. Their actions were deemed directly responsible for the deaths.

This case serves as a reminder of the stringent requirements for proving criminal liability, particularly when relying on inducement. The Supreme Court’s decision emphasizes the importance of credible witness testimony and the prosecution’s duty to eliminate reasonable doubt. The Ambagan ruling also underscores that the mere utterance of angry words does not automatically equate to criminal liability for the actions of others. The prosecution must prove a direct causal link between the words and the subsequent crime.

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: Albert G. Ambagan, Jr. vs. People, G.R. Nos. 204481-82, October 14, 2015