People v. Cabiltes
REITERATIONFacts
The Antecedents: The case involves an appeal by Teofilo Cabiltes and Gonzalo Cabiltes from the decision of the Court of First Instance of Leyte finding them guilty of murder. An amended complaint initially charged seven individuals with the murder of Esteban Mesias. However, Domingo Cabiltes, Carlito Morales, and Arturo Allego were excluded due to grave doubt regarding their participation. Teofilo Cabiltes, Gonzalo Cabiltes, and Diego Cabiltes were indicted in an information, alleging that on or about May 31, 1960, they conspired and confederated to assault and kill Esteban Mesias with a bolo, knives, and stones, inflicting fatal injuries. The prosecution's version states that Teofilo Cabiltes, upon learning his father was assaulted by Mesias, proposed revenge. This plan was agreed upon by several others, including Gonzalo Cabiltes. Teofilo armed himself and, along with Gonzalo and others, encountered Mesias. Teofilo stabbed Mesias in the back, and Gonzalo then stabbed him in the breast. After Mesias fell, they carried him to a canal, and Teofilo further hacked him. Diego Cabiltes fled, and Gonzalo ran to his aunt's house, where he was later arrested. Procedural History: The Court of First Instance of Leyte (Ormoc City) found Teofilo Cabiltes and Gonzalo Cabiltes guilty of murder, sentencing each to reclusión perpetua, and jointly and severally indemnifying the heirs of Esteban Mesias. Teofilo Cabiltes withdrew his appeal, leaving only Gonzalo Cabiltes' appeal for consideration. The Petition: Gonzalo Cabiltes challenged the credibility of the sole eyewitness for the prosecution, Faustino Alapan, citing inconsistencies in his affidavit and testimonies regarding his whereabouts at the time of the killing.
Issue(s)
Whether the inconsistencies in the testimony of the prosecution's eyewitness, Faustino Alapan, render his testimony unreliable. Whether the appellant, Gonzalo Cabiltes, participated in the conspiracy and commission of the murder of Esteban Mesias.
Ruling
The Court affirmed the judgment of the trial court in so far as the appellant Gonzalo Cabiltes is concerned. The appeal of Gonzalo Cabiltes was denied, and the decision finding him guilty of murder was affirmed in its entirety.
Ratio Decidendi
On the credibility of the eyewitness, Faustino Alapan: The Court found no material contradiction of consequence in Alapan's testimony when compared to his affidavit. While there were apparent discrepancies regarding his exact location at specific times, the Court reasoned that these were trivial mistakes, not indicative of a desire to pervert the truth. The Court noted that Alapan was a young, illiterate barrio lad, and such honest lapses do not necessarily impair his credibility. Instead, they could be seen as a demonstration of good faith and confirmation that he was not a rehearsed witness. The Court also considered that Alapan bore no ill-feeling towards the accused and had no apparent motive to perjure himself. The Court emphasized that the inconsistencies were not significant enough to discard his testimony, especially since his core assertions regarding the participation of Teofilo and Gonzalo Cabiltes in the stabbing remained consistent. The Court further highlighted that Alapan's testimony was indirectly corroborated by other evidence, including the autopsy findings and the extrajudicial confession of Teofilo Cabiltes. On the participation of Gonzalo Cabiltes in the conspiracy and murder: The Court found proof beyond reasonable doubt that Gonzalo Cabiltes, acting in conspiracy, participated in the killing. His disclaimer of knowledge of the plot was negated by circumstances showing he was aware of the plan, joined the group, and was present during the stabbing. The Court found his claim of fleeing after Teofilo stabbed Mesias to be of doubtful veracity, arguing that natural human instinct would compel him to aid his nephew. The Court found it more reasonable to believe Alapan's testimony that Gonzalo also stabbed Mesias. Corroboration was found in the autopsy findings, which indicated the use of more than one weapon by more than one person, and the physical evidence, specifically a stab wound consistent with the small bolo identified as wielded by Gonzalo. Furthermore, the extrajudicial confession of Teofilo Cabiltes, stating that Gonzalo helped in stabbing Mesias, served as corroborative evidence. The Court also dismissed the claim that the confessions were coerced, finding no motive for the police to fabricate the statements and noting the voluntary confirmation of the contents by the affiants before the justice of the peace.
Main Doctrine
The inconsistencies in the testimony of an eyewitness, particularly a young, illiterate barrio lad, may be considered trivial mistakes and do not necessarily impair his credibility, especially when the contradictions are not material and do not indicate a desire to pervert the truth. Such honest lapses can be considered as a demonstration of good faith and confirmation that the witness was not rehearsed. Furthermore, an extrajudicial confession, while admissible only against the person who made it, can serve as corroborative evidence of other facts that tend to establish the guilt of a co-defendant, especially when conspiracy is established.