Facts:

• The case "El Pueblo de Filipinas vs. Guevarra" was decided on September 30, 1946, by the Supreme Court of the Philippines.
• Emilio and Ciriaco Guevarra appealed their convictions.
• The incident occurred on December 12, 1943, in the barrio of Masalukot II, Candelaria, Quezon Province.
• Eulogio Laylo, his wife Rosario Magcawas, and their three young children were at home when three armed men forcibly entered their house.
• The intruders tied up Eulogio and subsequently shot him dead.
• Rosario identified the assailants as Fernando Guevarra and his sons, Marcos, Emilio, and Ciriaco.
• The intruders stole valuables worth P2,660 and threatened Rosario not to report the crime.
• The lower court convicted Fernando Guevarra and his sons of robbery with homicide, sentencing them to reclusion temporal and ordering them to pay indemnities.
• During the appeal, it was noted that Fernando and Marcos had died, leaving only Emilio and Ciriaco to contest their convictions.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled in favor of Emilio and Ciriaco Guevarra, acquitt...(Unlock)

Ratio:

• The Court's ratio decidendi centered on the reliability of Rosario Magcawas' testimony.
• A single uncorroborated testimony can suffice for a conviction, but it must withstand rigorous scrutiny against the surrounding circumstances.
• The Court found inconsistencies and delays in Rosario's identification of Emilio and Ciriaco.
• Initially, Rosario made no mention of Emilio and Ciriaco in her statements immediately following the incident.
• It was only weeks later, during the preliminary investigation and trial, that she provided detailed accounts implicating them.
• This sudden emergence of d...continue reading