### Facts:
This case involves Albert G. Ambagan, Jr., former Mayor of Amadeo, Cavite, and his conviction for the crime of double homicide arising from the deaths of SPO2 Reynaldo Santos and Domingo Bawalan on July 5, 2004. Ambagan was accused of inducing other accused public officers to commit the crime.
On April 6, 2005, two Informations were filed against Ambagan and others for homicide. The trial was held in the Sandiganbayan due to Ambagan’s position. The prosecution presented 18 witnesses, including close relatives of the victims and officers who responded to the crime scene. Among these witnesses, Victor J. Patam and Ronnel Bawalan were present at or near the crime scene, providing key testimony about the sequence of events leading to the shooting. The defense contested the witnesses’ credibility and offered alternative narratives through their testimonies, including that of Ambagan.
The Sandiganbayan convicted Ambagan, stressing particularly the testimony of Ronnel Bawalan, who claimed that he heard Ambagan order the shooting. Ambagan’s motion for reconsideration was denied, leading to the filing of a Petition for Review on Certiorari under Rule 45 of the Rules of Court in the Supreme Court, questioning the Sandiganbayan’s decision.
### Issues:
1. Whether the testimonies of the prosecution’s main witnesses were inconsistently contradictory.
2. Whether the court erred in failing to reconcile certain facts, such as the death of three of Ambagan’s men in the firefight and the absence of gunpowder on deceased Amparo.
3. Whether the court properly considered the possibility that Santos and Bawalan, allegedly being drunk, might have been the aggressors.
4. Whether Ronnel Bawalan was actually present and credible as a witness to the crime.
5. Whether Ambagan can be held guilty beyond reasonable doubt for the crimes charged as principal by inducement.
### Court’s Decision:
The Supreme Court, in a split decision, found that the evidence against Ambagan did not pass the test of moral certainty required for convicting an individual beyond reasonable doubt. The Court took notice of substantial inconsistencies and discrepancies in the testimonies of the prosecution’s key witnesses, particularly regarding whether Ambagan indeed ordered his men to open fire. Based on these doubts, the Supreme Court acquitted Ambagan of the charges for double homicide, holding that the evidence presented does not conclusively prove his guilt as principal by inducement.
### Doctrine:
The Court reiterated the doctrine that for a conviction to be made, the guilt of the accused must be proven beyond reasonable doubt. Where reasonable doubt exists, acquittal must follow.
### Class Notes:
Key Elements:
– Proof Beyond Reasonable Doubt: Any conviction must surmount this highest standard of proof in criminal law.
– Principal by Inducement: Involves determining whether the accused had induced others to commit a crime, with said inducement being the determining cause of the crime.
Historical Background:
– This case underscores the importance of credible witness testimony in proving beyond reasonable doubt, especially in criminal cases involving public officers. It also highlights the appellate review process in ensuring the just application of the law.
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