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### Facts:
– **16 October 2001 to Early Hours of 17 October 2001:**
– At 8:00 p.m., petitioner Angel Ubales and the deceased, Mark Santos, were drinking liquor with a group that included Jon-Jon, Solo Perez, and Jojo Santos in front of Mark’s house in Manila.
– Ubales and Mark had an argument about Mark’s cousin, which was seemingly resolved.
– After the carousal, which ended the next day at 1:00 a.m., Ubales and Mark went into Mark’s house.
– Both men left to reportedly head to Ubales’ house on J.P. Laurel Street.
– **17 October 2001:**
– By 3:00 a.m., Eduardo Galvan, a 65-year-old balut vendor, allegedly saw an argument between Mark and Ubales, and witnessed Ubales shooting Mark in the head.
– At around 3:55 a.m., SPO1 Eduardo Ko received a report of a body at the intersection of Jose P. Laurel St. and Matienza St., San Miguel, Manila. The police recovered a .38 caliber paltik revolver with three live bullets and one empty shell nearby.
– An autopsy confirmed Mark died from a gunshot wound to the forehead.
– **25 October 2001:**
– Laila Cherry Cruz sought police assistance to apprehend Ubales after spotting him near Malacañang.
– SPO2 Rosales Fernandez arrested Ubales without a warrant, and the latter voluntarily accompanied the officer for investigation and a medical exam.
– **5 November 2001:**
– P/Chief Inspector Carlos Mendez received and examined the .38 caliber paltik revolver.
– **Trial and Evidence:**
– The prosecution presented several witnesses, including Eduardo Galvan, SPO1 Ko, Laila Cherry Cruz, SPO2 Fernandez, and a forensic firearms examiner.
– Defense presented Ubales, asserting alibi, claiming he was either at home or at a friend’s house during the incident.
– Other defense witnesses corroborated Ubales’ account.
– Ubales’ motion to demur the evidence was denied by the trial court, and the defense was directed to present evidence.
– **Trial Court Decision:**
– On 20 July 2004, Ubales found guilty of homicide and sentenced to 10 years Prision Mayor as minimum and 14 years, 8 months, and 1 day Reclusion Temporal as maximum.
– Ubales ordered to pay civil indemnity, moral damages, and actual damages.
– **Court of Appeals Decision:**
– On 30 November 2006, the Court of Appeals affirmed the conviction but added P25,000 as temperate damages.
Ubales then filed a petition for review on certiorari under Rule 45, putting forward two main issues.
### Issues:
1. **Whether the evidence for the prosecution proved that Ubales committed the crime charged beyond reasonable doubt.**
2. **Whether the additional award of twenty-five thousand pesos (P25,000.00) as temperate damages was in accordance with law and relevant decisions of the Supreme Court.**
### Court’s Decision:
1. **Evidence of Guilt Beyond Reasonable Doubt:**
– The Court found inconsistencies and improbabilities in Eduardo Galvan’s testimony which cast doubt on its reliability. The testimony failed to meet the test of moral certainty required for a conviction.
– The lack of corroborative evidence and ballistic examination linking the recovered gun to the crime also weakened the prosecution’s case.
– Ubales’ willingness to cooperate with the police and undergo medical examination highlighted a lack of flight behavior, inconsistent with guilt.
– The Supreme Court acquitted Ubales due to reasonable doubt, emphasizing the principle that it is preferable to acquit ten guilty individuals than to convict one innocent person.
2. **Temperate Damages:**
– Given the acquittal of Ubales, the discussion on temperate damages was rendered moot.
### Doctrine:
– **Reasonable Doubt and Credibility of Witnesses:** Testimonies must be credible in themselves and conform to common human experience. Doubts arising from witness testimonies undercut the certainty needed for conviction.
– **Preference for Acquittal in Cases of Doubt:** Legal doctrine prioritizes acquitting the accused in the presence of reasonable doubt to prevent unjust conviction.
### Class Notes:
– Application of the “reasonable doubt” standard in criminal trials.
– The importance of the credibility of eyewitness testimony.
– The legal principle that flight can be interpreted as evidence of guilt.
– The necessity of corroborative evidence in upholding a conviction.
– **Relevant Statute:** Rule 133, Sec. 2, of the Rules of Court – requiring moral certainty for conviction.
### Historical Background:
– The decision reflects ongoing judicial scrutiny of due process and evidentiary standards in Philippine criminal law. Emphasizing the protection of individual rights, the ruling upholds stringent requirements for securing a conviction, reinforcing the fundamental principle of reasonable doubt as a safeguard against wrongful imprisonment. This case highlights the judiciary’s role in rectifying potential miscarriages of justice amidst legal proceedings.
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