G.R. No. 130209; March 14, 2001
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LARRY LAVAPIE, et al., accused. LARRY LAVAPIE and SANTOS SAN PASCUAL, SR., accused-appellants.

FACTS

Accused-appellants Larry Lavapie and Santos San Pascual, Sr., along with others, were charged with the murder of Sonny Sierva on March 29, 1989, in Camarines Sur. The prosecution’s case hinged on the testimonies of eyewitnesses Domingo Samonte and Jenny Cordial. Samonte testified that while walking home with the victim, they encountered a group. He identified San Pascual, Sr. as the one who held Sierva’s hands behind his back, and Lavapie as the one who then hacked Sierva on the neck with a bolo. Cordial, arriving shortly after with another companion, testified to finding Sierva’s body and seeing Lavapie standing nearby holding a bolo. The defense presented alibis and denied involvement.
The Regional Trial Court convicted Lavapie and San Pascual, Sr. of murder, sentencing them to reclusion perpetua. They appealed, arguing the trial court erred in giving credence to the prosecution witnesses’ testimonies.

ISSUE

Whether the guilt of accused-appellants Larry Lavapie and Santos San Pascual, Sr. for the crime of murder was proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted the accused-appellants. The Court found the testimonies of the key prosecution witnesses, Domingo Samonte and Jenny Cordial, to be replete with material inconsistencies and improbabilities that eroded their credibility and failed to establish guilt beyond reasonable doubt.
Samonte’s testimony was deemed inherently unbelievable. He claimed to have witnessed the hacking from a close distance yet took no action, did not immediately report the crime, and hid until dawn without seeking help, which the Court found contrary to human experience. Furthermore, his identification of the appellants was questionable given the alleged darkness of the night. Cordial’s testimony was also problematic. She stated it was too dark to recognize the other persons at the scene, yet she could clearly describe Lavapie’s bolo as “shiny and sharp” and “clear and clean,” and claimed to recognize Lavapie himself from several meters away. These contradictory assertions regarding visibility cast serious doubt on the reliability of her identification. When the testimony of a witness is fraught with inconsistencies on material points, it cannot sustain a conviction. The prosecution thus failed to overcome the constitutional presumption of innocence. The Court ordered the immediate release of the appellants unless detained for another lawful cause.