“The court said the alleged failure of the victim to turn over a lost gun desired by the two appellants, is not a sufficient motive for them to kill their own nephew“
In People of the Philippines v. Flora, et al., “appellants did not present any proof of improper motive on the part of the eyewitnesses in pointing to the Flora brothers as the perpetrators of the crime.
“There is no history of animosity between them” (G.R. 125909, June 23, 2000).
“Emerita Roma and Flor Espinas were merely innocent bystanders when hit by gunfire. Where eyewitnesses had no grudge against the accused, their testimony is credible. In the absence of ulterior motive, mere relationship of witnesses to the victim does not discredit their testimony” (G.R. 125909, June 23, 2000).
In the case of People of the Philippines v. Pisalvo, et al. “[e]ven as the prosecution tried to establish the motive for the killing, this alone cannot replace proof beyond reasonable doubt.
“The widow of the victim claims that the two defendants who are uncles of the victim, threatened and attempted to kill him before the fatal night because the victim failed to bring to them a lost gun they wanted” (G.R. L-32886, Oct. 23, 1981).
“This Court has emphatically ruled that even when there exists an apparent motivation for the murder — that the accused was impelled to instigate the crime as the victim was a brother of the then mayor, who presumably reneged on his promise to give way in the 1971 election for the position of mayor in favor of the accused — there is still need for evidence, both competent and credible, to prove his guilt and that of his co-accused” (G.R. L-32886, Oct. 23, 1981 citing People vs. Roa).
“The alleged failure of the victim to turn over a lost gun desired by the two appellants, is not a sufficient motive for them to kill their own nephew. It is unnatural for two uncles to accord more value to a gun than the life of their nephew” (G.R. L-32886, Oct. 23, 1981).
In the People of the Philippines v. Roa case, the Supreme Court, in reversing the judgment of conviction against the accused, further said that “[t]he proof against him must survive the test of reason; the strongest suspicion must not be permitted to sway judgment.
“The conscience must be satisfied that on the defendant could be laid the responsibility for the offense charged…” (cited in G.R. L-32886, Oct. 23, 1981).
In the case of People of the Philippines v. Aquino, cited in the Pisalvo case, the Supreme Court reiterated “that assuming arguendo that the accused had a very strong motive to eliminate Benigno Pascua, such motive cannot take the place of proof beyond reasonable doubt, sufficient to overthrow the presumption of innocence” (G.R. L-36020, Oct. 30, 1979).
“[T]he existence of a motive alone would not be proof that he actually committed the offense. In support of his contention, appellant invokes the decision of this Court in the case of People vs. Marcos, et al. (70 Phil., 468) wherein it was stated that ‘the existence of a motive alone though perhaps an important consideration, is not proof of the commission of the crime, much less of the guilt of the defendants-appellants’” (People of the Philippines v. Martinez Godinez, G.R. L-12268, Nov. 28, 1959).
The principle invoked is not applicable to the Martinez Godinez case.
“It relates to cases where there is no other evidence as to the identity of the offender.
“Motive alone cannot serve as the link between the [perpetrator and the] offense… [I]t is not disputed that the deceased died as a consequence of a bullet wound which was discharged by appellant from his .45 caliber pistol” (G.R. L-12268, Nov. 28, 1959).