People v.

Cajumocan
FACTS:

On the night of September 30, 1999, Apolinario Mirabueno was shot dead
while sleeping. The alleged gunman, Cornelio Cujumocan, was identified by
Apolinario’s brother who was present during the shooting. On his testimony
during his trial at the RTC, Cajumocan stated that he was on duty at the time
of the shooting, that the police came the next morning following the day of
shooting and invited him to the police station, and that he underwent a
paraffin test which showed that he was negative for poweder burns. However,
despite his alibi and the paraffin test result, the RTC found Cajumocan guilty
beyond reasonable doubt of the crime of Murder.

ISSUE:

Whether the trial court erred in not considering the negative findings of the
paraffin test conducted as conclusive proof of innocence of the accused.

RULING:

The Supreme Court affirmed the ruling of the RTC, finding Cajumocan guilty
beyond reasonable doubt of Murder.

RATIO:

The Supreme Court in ruling stated that, Paraffin tests are extremely
unreliable in use and that it can only establish the presence or absence of
nitrates. It cannot establish that the source of the nitrate was the discharge of
firearms since nitrates are also found in substances other than gunpowder.
Paraffin tests merely corroborate direct evidence that may be presented by the
prosecution. The Supreme Court further stated that the positive, clear and
categorical testimony of the lone eyewitness to the crime deserves full merit in
both probative weight and credibility over the negative results of the paraffin
test conducted on the appellant. Verily, establishing the identity of the
malefactor through the testimony of the witness is the heart and causes of the
prosecution. All other matters, such as the paraffin test, are of lesser
consequence where there is positive identification by the lone eyewitness, Leo
Mirabueno, of appellant as the perpetrator of the crime. Hence, a paraffin test
cannot be considered as conclusive proof of appellant’s innocence.