After going over the records of this case, the Court is unable to sustain the findings of fact
and conclusion reached by the courts below. The totality of the evidence shows that the proximate
cause of the collision was the reckless negligence of the tricycle driver, who hastily overtook another
vehicle while approaching a blind curve, in violation of traffic laws.
Based on the evidence on record, it is crystal clear that the immediate and proximate cause
of the collision is the reckless and negligent act of Quintin Catubig, Jr. and not because the Ceres
Bus was running very fast
We should eschew speculation and passion. We should not allow angles or theories not
supported by the evidence on record to distract us.
Basic under the rules of evidence is that a witness can only testify on facts within his or her
personal knowledge. This personal knowledge is a substantive prerequisite in accepting testimonial
evidence establishing the truth of a disputed fact.
ROBERT DA JOSE and FRANCISCO OCAMPO y ANGELES, Petitioners,
vs.
CELERINA R. ANGELES, EDWARD ANGELO R. ANGELES and CELINE ANGELI R.
ANGELES, G.R. No. 187899 October 23, 2013
A punctilious examination of the MeTC’s Order, which the RTC sustained, will show that Daluraya’s
acquittal was based on the conclusion that the act or omission from which the civil liability may arise
did not exist, given that the prosecution was not able to establish that he was the author of the crime
imputed against him. Such conclusion is clear and categorical when the MeTC declared that "the
testimonies of the prosecution witnesses are wanting in material details and they did not sufficiently
establish that the accused precisely committed the crime charged against him." Furthermore, when
37
Marla sought reconsideration of the MeTC’s Order acquitting Daluraya, said court reiterated and
firmly clarified that "the prosecution was not able to establish that the accused was the driver of the
Nissan Vanette which bumped Marina Oliva" and that "there is no competent evidence on hand
38
which proves that the accused was the person responsible for the death of Marina Oliva." 39
in view of the failure of the prosecution to sufficiently establish that he was the author of the
crime ascribed against him
A nexus of logically related circumstances, however, rendered the testimony of Flores as
highly suspect. His testimony is laden with improbabilities that detract from his credibility. The totality
of the evidence for the prosecution leaves much to be desired. Somehow, the Court cannot help but
entertain serious doubts on the veracity of the malefactor's identity. It is almost as if it was merely
contrived to pin criminal culpability upon De Guzman.
the Court stated that the identification of an accused by an eyewitness is a vital piece of
evidence and most decisive of the success or failure of the case for the prosecution. In the case at
bench, however, the inconclusive and unreliable identification by Flores of De Guzman as the culprit
failed to break the barrier of proof beyond reasonable doubt.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee,
vs.
HERMOGENES DE GUZMAN @ Mong, G.R. No. 192250 July 11, 2012
n People v. Faustino,19
Citing: 19
394 Phil. 236, 259 (2000).
In light of the weakness in the prosecution's case, the alibi of De Guzman assumes credence and
importance. While alibi is a weak defense and the rule is that it must be proved to the satisfaction of
the court, the said rule has never been intended to change the burden of proof in criminal cases.
Otherwise, an absurd situation will arise wherein the accused is put in a more difficult position where
the prosecution evidence is vague and weak as in the present case. The burden of proof still lies in
30
the prosecution to establish that De Guzman was responsible for the killing.
It is oft-repeated that a finding of guilt must rest on the evidence of the prosecution not on the
weakness or even absence of evidence for the defense. Thus, it is required that every circumstance
favoring the innocence of the accused must be duly taken into account. The proof against him must
survive the test of reason and the strongest suspicion must not be permitted to sway judgment. In 31
the case at bench, the evidence for the prosecution was unable to pass the exacting test of moral
certainty that the law demands. In People v. Fernandez, this Court has aptly said:
32
It is better to liberate a guilty man than to unjustly keep in prison one whose guilt has not been
proved by the required quantum of evidence. Hence, despite the Court's support of ardent crusaders
waging all-out war against felons on the loose, when the People's evidence fails to prove indubitably
the accused's authorship of the crime of which they stand accused, it is the Court's duty -- and the
accused's right -- to proclaim their innocence. Acquittal, therefore, is in order.
he evidence of the prosecution must stand on its own weight and not rely on the weakness
of the defense.
GUILBEMER FRANCO, Petitioner
vs.
PEOPLE OF THE PHILIPPINES, Respondent G.R. No. 191185 February 1, 2016
Citing: 59
People v. Tan, 432 Phil. 171, 199 (2002).
The facts and circumstances proven by the prosecution, taken together, are not sufficient to
justify the unequivocal conclusion that Franco feloniously took Nakamoto's cell phone. No other
convincing evidence was presented by the prosecution that would link him to the theft. The fact57
Franco took a cell phone from· the altar does not necessarily point to the conclusion that it was
Nakamoto's cell phone that he took. In the appreciation of circumstantial evidence, the rule is that
the circumstances must be proved, and not themselves presumed. The circumstantial evidence
must exclude the possibility that some other person has committed the offense charged. 58
))))))))))
Pineda underscored that "[t]he more important duty of the prosecution is to prove the identity of the
perpetrator and not to establish the existence of the crime." Establishing the identity of perpetrators
94
is a difficult task because of this jurisdiction's tendency to rely more on te
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee
vs.
CRISENTE PEPAÑO NUÑEZ, Accused-Appellant G.R. No. 209342 OCTOBER 4, 2017
Citing: 4 73 Phil. 517 (2004)
000
The burden of such proof rests with the prosecution, which must rely on the strength of its case
rather than on the weakness of the case for the defense. Proof beyond reasonable doubt, or that
quantum of proof sufficient to produce a moral certainty that would convince and satisfy the
conscience of those who act in judgment, is indispensable to overcome the constitutional
presumption of innocence. 23
In every criminal conviction, the prosecution is required to prove two things beyond reasonable
doubt: first, the fact of the commission of the crime charged, or the presence of all the elements of
the offense; and second, the fact that the accused was the perpetrator of the crime. 24
GUILBEMER FRANCO, Petitioner
vs.
PEOPLE OF THE PHILIPPINES, Respondent G.R. No. 191185 February 1, 2016
Citing:
People v. Villanueva, 427 Phil. 102, 128 (2002).
23
People v. Santos, 388 Phil. 993, 1004 (2000).
24
))))))))
Conviction in criminal actions demands proof beyond reasonable doubt. Rule 133, Section 2 of the
Revised Rules on Evidence states:
Section 2. Proof beyond reasonable doubt. - In a criminal case, the accused is entitled to an
acquittal, unless his guilt is shown beyond reasonable doubt. Proof beyond reasonable doubt does
not mean such a degree of proof as, excluding possibility of error, produces absolute certainty. Moral
certainty only is required, or that degree of proof which produces conviction in an unprejudiced mind.
While not impelling such a degree of proof as to establish absolutely impervious certainty, the
quantum of proof required in criminal cases nevertheless charges the prosecution with the immense
responsibility of establishing moral certainty, a certainty that ultimately appeals to a person's very
conscience. While indeed imbued with a sense of altruism, this imperative is borne, not by a mere
abstraction, but by constitutional necessity:
This rule places upon the prosecution the task of establishing the guilt of an accused, relying on the
strength of its own evidence, and not banking on the weakness of the defense of an accused.
Requiring proof beyond reasonable doubt finds basis not only in the due process clause of the
Constitution, but similarly, in the right of an accused to be "presumed innocent until the contrary is
proved." "Undoubtedly, it is the constitutional presumption of innocence that lays such burden upon
the prosecution." Should the prosecution fail to discharge its burden, it follows, as a matter of course,
that an accused must be acquitted. As explained in Basilio v. People of the Philippines:
XXX
Well-entrenched in jurisprudence is the rule that the conviction of the accused must rest, not on the
weakness of the defense, but on the strength of the prosecution. The burden is on the prosecution to
prove guilt beyond reasonable doubt, not on the accused to prove his innocence. 81
CAPISTRANO DAAYATA, DEXTER SALISI, and BREGIDO MALA CAT, JR., Petitioners
vs
PEOPLE OF THE PHILIPPINES, Respondent G.R. No. 205745 March 8, 2017
))
The crucial issue in this case is the sufficiency of evidence to convict De Guzman. More particularly,
the Court has to inquire whether there had been sufficient identification of De Guzman as the
perpetrator of the crime.
In every criminal case, the task of the prosecution is always two-fold, that is, (1) to prove beyond
reasonable doubt the commission of the crime charged; and (2) to establish with the same quantum
of proof the identity of the person or persons responsible therefor, because, even if the commission
of the crime is a given, there can be no conviction without the identity of the malefactor being
likewise clearly ascertained. 15
G.R. No. 192250 July 11, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee,
vs.
HERMOGENES DE GUZMAN @ Mong, Accused-Appellant.
citing:
15
People v. Bacalso, 395 Phil. 192, 199 (2000).
15
People v. Bacalso, 395 Phil. 192, 199 (2000).
)))
With a cloud of doubt continuously hovering, the mind cannot rest easy.
)))
***
Not only do these doubts persist, details disclosed by the prosecution itself - taken together with how
the defense accounted for the events of December 16 and 17, 1995 - demonstrate the dubiety of the
prosecution's claims.
)))
In the Court stated that the identification of an accused by an eyewitness is a vital piece of
19
evidence and most decisive of the success or failure of the case for the prosecution.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee,
vs.
HERMOGENES DE GUZMAN @ Mong, Accused-Appellant. G.R. No. 192250 July 11,
2012
Citing: People v. Faustino,394 Phil. 236, 259 (2000).
n the case at bench, the testimony of Flores, the lone eyewitness of the prosecution does not bear
the earmarks of truth and, hence, not credible.
))))))))))
It is oft-repeated that a finding of guilt must rest on the evidence of the prosecution not on the
weakness or even absence of evidence for the defense. Thus, it is required that every circumstance
favoring the innocence of the accused must be duly taken into account. The proof against him must
survive the test of reason and the strongest suspicion must not be permitted to sway judgment. In31
the case at bench, the evidence for the prosecution was unable to pass the exacting test of moral
certainty that the law demands. In People v. Fernandez, this Court has aptly said:
32
It is better to liberate a guilty man than to unjustly keep in prison one whose guilt has not been
proved by the required quantum of evidence. Hence, despite the Court's support of ardent crusaders
waging all-out war against felons on the loose, when the People's evidence fails to prove indubitably
the accused's authorship of the crime of which they stand accused, it is the Court's duty -- and the
accused's right -- to proclaim their innocence. Acquittal, therefore, is in order.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee,
vs.
HERMOGENES DE GUZMAN @ Mong, G.R. No. 192250 July 11, 2012
Citing: 32
People v. Fernandez 434 Phil. 435, 455 (2002).
--
in People vs. Faustino, the Court has observed that the identification of an accused by an
17
eyewitness is a vital piece of evidence and most decisive of the success or failure of the case for the
prosecution,
G.R. No. 129055 September 25, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee,
vs.
EDGAR BACALSO
Citing G.R. No. 129220, 06 September 2000.
)))))))))
It is ineluctable that the identification of the perpetrator of the crime bears heavily on the
reasonableness or probability of the testimony of the prosecution witness.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee,
vs.
EDGAR BACALSO G.R. No. 129055 September 25, 2000
))))
Proving the identity of the accused as the malefactor is the prosecution's primary responsibility. The
identity of the offender, like the crime itself, must be established by proof beyond reasonable doubt.
Indeed, the first duty of the prosecution is not to prove the crime but to prove the identity of the
criminal, for even if the commission of the crime can be established, there can be no conviction
without proof of identity of the criminal beyond reasonable doubt.26
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee
vs.
JUVY D. AMARELA AND JUNARD G. RACHO G.R. No. 225642-43 January 17, 2018
People v. Caliso, 675 Phil. 742, 752 (2011)
Citing: People v. Caliso, 675 Phil. 742, 752 (2011)
))))))))))
In ,25 we declared that:
A successful prosecution of a criminal action largely depends on proof of two things: the identification
of the author of the crime and his actual commission of the same. An ample ,proof that a crime has
been committed has no use if the prosecution is unable to convincingly prove the offender's identity.
The constitutional presumption of innocence that an accused enjoys is not demolished by an
identification that is full of uncertainties.26
G.R. No. 208446, April 06, 2016
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JONEL VARGAS Y RAMOS, JERIENALD
VILLAMERO Y ESMAN, ARMANDO CADANO @ MANDO, JOJO ENORME @ JOJO, RUTHER
GARCIA @ BENJIE/LOLOY, AND ALIAS TABOY, ACCUSED, JONEL VARGAS Y RAMOS,
JERIENALD VILLAMERO Y ESMAN, Accused-Appellants.
DECISION
Citing: People v. Tumambing 659 Phil. 544 (2011).
))))))))))))
The Prosecution must further prove the participation of the accused in the commission of the
offense. In doing all these, the Prosecution must rely on the strength of its own evidence, and
not anchor its success upon the weakness of the evidence of the accused. The burden of
proof placed on the Prosecution arises from the presumption of innocence in favor of the
accused that no less than the Constitution has guaranteed. Conversely, as to his innocence,
the accused has no burden of proof, that he must then be acquitted and set free should the
Prosecution not overcome the presumption of innocence in his favor. In other words, the
weakness of the defense put up by the accused is inconsequential in the proceedings for as
long as the Prosecution has not discharged its burden of proof in establishing the
commission of the crime charged and in identifying the accused as the malefactor
responsible for it. 20
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee,
vs.
CARLITO CLARO y MAHINAY, Accused-Appellant. G.R. No. 199894 April 5, 2017
))
the weakness of the defense put up by the accused is inconsequential in the proceedings for as
long as the Prosecution has not discharged its burden of proof in establishing the commission of the
crime charged and in identifying the accused as the malefactor responsible for it. G.R. No. 194234
29
June 18, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee,
vs.
JAYSON CRUZ y TECSON, Accused-Appellant.
)))
The Prosecution must further prove the participation of the accused in the commission of the
offense. In doing all these, the Prosecution must rely on the strength of its own evidence, and not
15
anchor its success upon the weakness of the evidence of the accused. The burden of proof placed
on the Prosecution arises from the presumption of innocence in favor of the accused that no less
than the Constitution has guaranteed.16
ANNA LERIMA PATULA, Petitioner,
vs.
PEOPLE OF THE PHILIPPINES, Respondent. G.R. No. 164457 April 11, 2012