THE Supreme Court held that not all alibis or denials are fabricated, especially if the prosecution failed to prove beyond a reasonable doubt the guilt of the accused.
This was the gist of the ruling promulgated on May 7, 2025 where the SC’s Third Division, through Associate Justice Japar Dimaampao, cleared Marvin Nuguid of murder for allegedly shooting Dutchman Wilhelmus Johannes Joseph Geertman to death on July 3, 2012.
Geertman was the executive director of the non-government organization Alay Bayan Incorporated, engaged in disaster preparedness, at the time of his death.
In acquitting Nuguid, the high court held that the prosecution failed to sufficiently establish his guilt.
Concurring with the ruling are Associate Justice Alfredo Benjamin Caguioa, Henri Jean Paul Inting, and Samuel Gaerlan.
Records of the case showed that Nuguid, along with three others, was initially charged with murder and robbery over Geertman’s killing.
The unidentified men who shot Geertman at the premises of Alay Bayan in San Fernando, Pampanga, fled the crime scene and it was only in 2014 when the police searched Nuguid’s house and arrested him for the crime.
The San Fernando City RTC convicted Nuguid of murder and sentenced him to life imprisonment but acquitted him of the crime of robbery.
In convicting Nuguid for murder, the RTC gave great weight to the testimonies of prosecution witnesses as it rejected his denial.
The RTC also pointed to the differing alibi of Nuguid and his common-law wife.
On appeal, the Court of Appeals affirmed Nuguid’s conviction, prompting him to elevate the case to the SC.
In clearing Nuguid, the SC held that the RTC and CA committed reversible error in hastily convicting him based on questionable evidence.
“After a punctilious review of the case, the Court resolves to acquit Nuguid on the ground of reasonable doubt. The lower courts committed reversible error in hastily convicting Nuguid based on questionable evidence. It is a basic and immutable principle in criminal law that an accused individual cannot be convicted if there is a reasonable doubt in his or her commission of a crime,” the SC held.
“Indeed, proof of guilt beyond a reasonable doubt must be adduced by the prosecution; otherwise, the accused must be acquitted, even if, on the face of it, he or she appears to be most suspicious or even if there is no other possible or identifiable perpetrator on the records despite there having been a crime committed,” the SC added.
The high court said several witnesses presented by the prosecution did not personally witness the crime; thus, they cannot testify as to the identity of the shooter.
As to those presented by the prosecution as eyewitnesses, the SC said one of them failed to provide a concrete description of the assailant and eventually acknowledged she did not see who fired the gun that killed Geertman, while another admitted he could not identify the perpetrators, let alone the shooter himself.
“The foregoing statements (witnesses) taken together make it highly doubtful that the prosecution was able to identify Nuguid as the perpetrator of the crime; thus, the Court has its misgivings if it was indeed Nuguid who shot Geertman. To the Court’s minds, these inconsistencies are far from minor as they pertain to the capability of said witnesses to ascertain the identity of the shooter who committed this heinous crime beyond a reasonable doubt,” the SC explained.
It stressed that it is elementary that the prosecution must rely on the strength of its evidence and not on the weakness of that of the defense.
Thus, while it held that Nuguid relied on denials and while these are the weakest evidence of all, the high court said not all alibis should be regarded as fabricated.
“Since in the case at bench, the evidence for the prosecution is weak and betrays a lack of concreteness, Nuguid’s defense of denial assumes importance,” the SC said.
Aside from the testimony of its witnesses, the high court said the prosecution also failed to provide legitimate and compelling evidence to secure Nuguid’s conviction.
“With this, Nuguid’s justification of alibi finds stronger ground, and the Court is thus obliged to favor it while taking into absolute consideration the premise that reasonable doubt is sufficient to acquit an accused individual of the crime,” the SC added.
