CRIMINAL PROCEDURE | PEOPLE V. NUÑEZ, G.R. NO. 209342, 4 OCTOBER 2017

PEOPLE V. NUÑEZ,

G.R. NO. 209342, 4 OCTOBER 2017

 

TOPIC/DOCTRINE

Conviction in criminal cases demands proof beyond reasonable doubt. While this does not require absolute certainty, it calls for moral certainty.

 

FACTS

This resolves an from thedecision of the Court of Appeals which affirmed with modification the Regional Trial Court Decision which found accused-appellant Crisente Pepaño Nuñez (Nuñez) guilty beyond reasonable doubt of robbery with homicide.

The prosecution’s case rises and falls on the testimonies of eyewitnesses Cruz and Perez. The necessity of their identification of Nuñez is so manifest that the prosecution saw it fit to recall them to the stand, even as it merely adopted the evidence already presented in the trial of Marciales and Nabia. Cruz’s and Perez’s testimonies centered on their supposed certainty as to how it was Nuñez himself, excluding any other person, who participated in the robbery and homicide.

 

ISSUE

Whether testimonies of eyewitnesses Cruz and Perez is sufficient to convict the accused.

 

RULING

No.

The court ruled that conviction in criminal cases demands proof beyond reasonable doubt. While this does not require absolute certainty, it calls for moral certainty. It is the degree of proof that appeals to a magistrate’s conscience: An accused has in his favor the presumption of innocence which the Bill of Rights guarantees. Unless his guilt is shown beyond reasonable doubt, he must be acquitted. This reasonable doubt standard is demanded by the due process clause of the Constitution which protects the accused from conviction except upon proof beyond reasonable doubt of every fact necessary to constitute the crime with which he is charged. The burden of proof is on the prosecution, and unless it discharges that burden the accused need not even offer evidence in his behalf, and he would be entitled to an acquittal. Proof beyond reasonable doubt does not, of course, mean such 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. The conscience must be satisfied that the accused is responsible for the offense charged. Eyewitnesses who have previously made admissions that they could not identify the perpetrators of a crime but, years later and after a highly suggestive process of presenting suspects, contradict themselves and claim that they can identify the perpetrator with certainty are grossly wanting in credibility. Prosecution that relies solely on these eyewitnesses’ testimonies fails to discharge its burden of proving an accused’s guilt beyond reasonable doubt.







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