G.R. No. 227005 - BDO Unibank, Inc. vs. Lao

On one of the last nights of November 1910 at about 10 o’clock, Pedro Cabigting, a curandero, was attending a patient in a house in the barrio of Bagbaguin, Caloocan.
While there, he heard a voice coming from the neighboring house of Macario Domingo utter the words, “Jesus, Maria y Jose, pardon me.”
Driven by concern, particularly because the neighbor’s wife was also sick, Cabigting went toward Domingo’s house and, upon approaching the yard (zaguan), he heard a groan.
Upon arrival, he observed a man lying on the ground with Macario Domingo and two other men, namely Pedra Mauricio and Celestino Ramirez, all of whom he recognized by their voices.

During the confrontation, Pedra Mauricio questioned Macario Domingo about his treatment of the victim.
Macario Domingo confessed that his actions were due to the victim’s incessant advances toward his daughter.
Domingo’s subsequent conversation with his companions revealed a plan: Pedra Mauricio suggested killing the victim outright, and Celestino Ramirez recommended concealing the body to avoid public exposure and resultant trouble.

Several days later, Julian Cleofas – brother of Doroteo Cleofas, who was later found dead – received an anonymous letter at his gate.
The letter informed him of the murder of his brother and provided details about the perpetrators and the burial location of the body.
Promptly, Julian Cleofas reported the incident to the Caloocan police, leading to prompt investigations by Lieutenant Dominador Aquino, Sergeant Indalecio Tan, and other officers.

Police investigations uncovered dried blood stains beneath the house of Macario Domingo, notably on bamboo strips used as flooring in the zaguan.
Guided by the clues from the anonymous letter, they discovered the body of Doroteo Cleofas in a wood area 120 meters from the house.
Despite an advanced state of decomposition, the body was identified by Julian Cleofas and confirmed by a professional medical examination, noting specific peculiarities such as a hemp cord on the wrist and signs of decomposition on various body parts.

The initial investigation led to the arrest of Pedro Mauricio and Macario Domingo, with evidence indicating their involvement in the violent death of Doroteo Cleofas.
In the trial, while Macario Domingo had died and Pedro Mauricio accepted his sentence of life imprisonment, Regina Domingo and Celestino Ramirez were also held responsible and sentenced to twenty years of reclusion temporal.
Testimony against Regina Domingo was primarily based on the statements of Lieutenant Dominador Aquino, who claimed she admitted to inviting the victim to the zaguan and striking him with a bolo under orders from her father, Macario Domingo.
Celestino Ramirez also faced charges based solely on the uncorroborated testimony of the curandero, Pedro Cabigting, and his own denials of participation.

Whether the testimony of Lieutenant Dominador Aquino, which attributed incriminating statements to Regina Domingo, was sufficient in itself to establish her guilt.
Whether the uncorroborated testimony of Pedro Cabigting could stand alone in establishing the guilt of Celestino Ramirez as either a co-principal or an accomplice.

The legitimacy of relying on single-witness recounts without supporting circumstantial evidence.
The absence of any incriminating evidence or corroborative circumstantial facts linking the defendants directly to the commission of the crime.

Whether the principle that a defendant is presumed innocent until proven guilty, particularly in the face of reasonable doubt, was properly observed in the trial.
The proper evaluation of judicial evidence when the only accusations against the defendants were uncorroborated and insufficient.