06 People v.

De Guzman
G.R. No. 192250 (2012)
Mendoza, J / aa

TOPIC: Identification of Persons

SUMMARY: Victim Noriel Urieta and the sole witness, his childhood friend Ignacio Flores were having a drink at
around 11pm when accused allegedly stabbed Urieta to death. The RTC found de Guzman guilty beyond
reasonable doubt. The CA affirmed. De Guzman appealed to the SC arguing that the evidence of the prosecution
(mainly the testimony of Flores) did not amount to proof beyond reasonable doubt. The Supreme Court agreed
with the accused and reversed his conviction because a nexus of logically related circumstances, rendered the
testimony of Flores as highly suspect. First, the incident took place during nighttime at 11:00 o'clock in a remote
barangay with no electric lighting in the surroundings and the only source of light then was the illumination of a
"moron" coming from a "peryahan." Under these circumstances, the Court finds the positive identification of
De Guzman by Flores hazy. (See doctrine). Second, Flores' story, that a certain Honato came to their aid and
brought the seriously wounded Urieta to the corner of the street but left thereafter supposedly to seek a
physician at the barangay hall, simply does not make sense. Third, the police officers had already a suspect, De
Guzman, in the killing of Urieta, even before Flores could give his statement and despite the absence of any
description from Flores himself as to how the culprit looked like.

DOCTRINES: Under these circumstances, the Court finds the positive identification of De Guzman by Flores
hazy. In People v. Faustino, 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.

PARTIES: Plaintiff-Appellee People of the Philippines

Accused-Appellant Hermogenes ‘Mong’ de Guzman

FACTS:

1. The Version of the Prosecution. On April 20, 2002 at around 11:00 o’clock in the evening, Noriel Urieta was
in Brgy. Francisco, Sablayan, Occidental Mindoro along with Ignacio Flores. They were drinking in the
amusement area. When they were about to leave the premises, accused de Guzman suddenly approached
them and without any provocation, suddenly stabbed Noriel Urieta with a knife on his left chest. After the
first blow, the victim was already kneeling down and accused proceeded to stab him three (3) more times.
He thereafter ran away.

Ignacio Flores called out for help and one Elmer Honato arrived to give them aid and bring the victim to a
secure place and thereafter proceeded to call for help. He waited for Elmer Honato to arrive but he did not
return anymore. With the condition of the victim uncertain and as he was afraid, he decided to leave the
victim and go home. (wtf!)

P a g e 1|3
 06 People v. De Guzman
G.R. No. 192250 (2012)
Mendoza, J / aa

Two days later, Police Officer Gamba, together with the father of Noriel Urieta and Gina Urieta, the wife of
Noriel Urieta, went to the house of Ignacio Flores in order to get the sworn statement as to the facts that
happened in this case. They were able to do so. Subsequently, an arrest on the person of Hermogenes de
Guzman was made. The Office of the Provincial Prosecutor then filed the information for murder thereafter.

2. The Version of the Defense. On the evening of April 21, 2002, Hermogenes De Guzman joined a drinking
spree at the house of a relative at barangay San Francisco. He was there from 8:00 o’clock in the morning
until 12:00 o’clock midnight, when he went home with his wife. The following day, he was drying palay when
his wife informed him that police officers were looking for him. He approached and inquired from the
officers what was the reason. He was told to go with them to the municipal hall for questioning. Thereat, he
was incarcerated because of his alleged involvement in a stabbing incident.

De Guzman does not personally know the victim, his wife, nor the supposed eyewitness, Ignacio Flores. He
(De Guzman) was not with Urieta when the former had a drinking spree. He denied having stabbed and
killed Urieta.

3. The RTC Ruling (Guilty). The RTC rendered judgment finding that the prosecution was able to establish with
certitude, through the credible testimony of prosecution witness Flores, that De Guzman stabbed and killed
Urieta.

4. The CA Decision (Affirmed). On appeal, the CA affirmed the judgment of conviction of De Guzman holding
that his guilt for the crime of murder was proven beyond reasonable doubt by the prosecution's evidence.

ISSUES: WON the conviction of de Guzman is supported by proof beyond reasonable doubt (NO, the
circumstances surrounding his identification is hazy)

RATIO: The case for the prosecution was woven basically on the testimony of Flores, who claimed to be a
childhood friend of Urieta. A nexus of logically related circumstances, however, rendered the testimony of Flores
as highly suspect

1. First, the condition of visibility at the time of the stabbing incident did not favor the witness Flores, as it did
not lend credence to his testimony. The incident took place during nighttime at 11:00 o'clock in a remote
barangay with no electric lighting in the surroundings and the only source of light then was the illumination
of a "moron" coming from a "peryahan." The Court observes that in his Sinumpaang Salaysay,Flores stated
that the "moron (de gas)" was just on the table where they were drinking which was contrary to what he
had testified in court. The distance of the "moron" in the "peryahan" from the site of the stabbing incident
was not disclosed either.

P a g e 2|3
 06 People v. De Guzman
G.R. No. 192250 (2012)
Mendoza, J / aa

Moreover, it is clear from the records that the stabbing incident was so swift for ample observation and
Flores, who had three bottles of beer, was admittedly very afraid so much so that all he did was to cry for
help.

Under these circumstances, the Court finds the positive identification of De Guzman by Flores hazy. In
People v. Faustino, 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.

2. Second, Flores' story, that a certain Honato came to their aid and brought the seriously wounded Urieta to
the corner of the street but left thereafter supposedly to seek a physician at the barangay hall, simply does
not make sense. His story about Honato being nebulous, the Court doubts if Flores ever shouted for help at
all. If he really did, many people in the "peryahan" would have surely come to their aid. Indeed, if he was a
childhood friend, he would not have second thoughts in bringing Urieta to the hospital himself. As he
merely abandoned his dying friend, one cannot help but harbor a suspicion. Furthermore, the reaction of
Flores, in hurriedly going home and leaving Urieta alone to die, was unnatural and contrary to common
human experience.

3. Third, the Court finds disturbing how the police officers were able to identify De Guzman as the killer of
Urieta. It is undisputed that on the day following the stabbing incident, De Guzman was invited by the police
officers to the municipal hall, was informed by them that he was a suspect in the commission of a crime and
then placed behind bars.

The sequence of events clearly reveals that the police officers had already a suspect, De Guzman, in the
killing of Urieta, even before Flores could give his statement and despite the absence of any description
from Flores himself as to how the culprit looked like. Curiously, no police officer was called to the witness
stand to shed light on the matter.

DISPOSITIVE: WHEREFORE, the appeal is GRANTED. Accused Hermogenes De Guzman is hereby ACQUITTED of
the crime charged against him and ordered immediately RELEASED from custody, unless he is being held for
some other lawful cause.

P a g e 3|3