People V Hassan
People V Hassan
People V Hassan
Ratio Decidendi
W/N the accused is guilty beyond reasonable doubt of the crime of murder.
No.
We hold that the evidence for the prosecution in its entirety does not satisfy the quantum of proof beyond reasonable
doubt required by the Constitution, the law, and applicable jurisprudence to convict an accused person. The said evidence
denies us the moral certainty which would allow us to pronounce, without uneasiness of conscience. In evaluating the
worth of the testimony of the lone eyewitness for the prosecution against the denial and alibi of the accused, value
judgment must not be separated from the constitutionally guaranteed presumption of innocence. When the evidence for
the prosecution and the evidence for the accused are weighed, the scales must be tipped in favor of the latter. This is
because of the constitutional presumption of innocence the accused enjoys as a counterfoil to the awesome authority of
the State that is prosecuting him. The element of doubt, if reasonable in this case, must operate against the inference of
guilt the prosecution would draw from its evidence. That evidence, as it happens, consists only of the uncorroborated
statement of the two policemen which, as previously observed, is flawed and therefore suspect.
The testimony of Jose Samson, the lone eyewitness, is weak and unconvincing. And so with the evidence sought to be
introduced by Police Corporal Carpio. We discover, for example, that the expert testimony of the medico-legal officer of
the National Bureau of Investigation, Dr. Valentin Bernalez, presented by the prosecution, contradicted, on material
points, the testimony of the lone eyewitness, Jose Samson. While Samson averred on the witness stand that he saw the
assailant stab the deceased “from behind on his chest” only once, the NBI medicolegal officer identified two stab wounds
one “at the front portion of the chest at the level and third rib, (sic) and another stab wound located at the left arm
posterior aspect.” The same medical expert also concluded from the nature and location of the chest wound, which was
the cause of death, that the same was “inflicted on the victim while the alleged accused was in front of him.”
And now as a penultimate observation, we could not help but note the total absence of motive ascribed to Usman for
stabbing Ramon, a complete stranger to him. While, as a general rule, motive is not essential in order to arrive at a
conviction, because, after all, motive is a state of mind, procedurally, however, for purposes of complying with the
requirement that a judgment of guilty must stem from proof beyond reasonable doubt, the lack of motive on the part
of the accused plays a pivotal role towards his acquittal. This is especially true where there is doubt as to the identity of
the culprit as when “the identification is extremely tenuous,” as in this case.
Ruling
WHEREFORE, the decision is hereby REVERSED, and the accused Usman Hassan y Ayun is ACQUITTED of the crime charged.
His release from confinement is hereby Ordered, unless he is held for another legal cause. With costs de oficio.