GR 141438; (February, 2003) (Digest)
G.R. No. 141438 -40 February 3, 2003
PEOPLE OF THE PHILIPPINES, appellee vs. LITO LIMPANGOG and JERRY LIMPANGOG, appellants.
FACTS
Appellants Lito and Jerry Limpangog were convicted by the Regional Trial Court of Ormoc City for Murder and two counts of Frustrated Murder. The charges stemmed from a nighttime incident on November 19, 1993, in Merida, Leyte, where victims Pedro Casimero, Rene Boy Casimero, and Jose Cabañero were stabbed. The prosecution’s case relied heavily on the testimony of Pedro Casimero, who identified the appellants as the assailants. He testified that after a dispute over a motorcab fare, the appellants attacked him and his companions. The defense, however, presented an alibi, claiming Lito Limpangog was at a different location attending a wake, supported by the testimony of a barangay official. During the pendency of the appeal, accused Jerry Limpangog died.
ISSUE
The core issue is whether the prosecution proved the guilt of the appellants beyond reasonable doubt, particularly in light of the credibility of the lone eyewitness and the strength of the alibi presented by the defense.
RULING
The Supreme Court ACQUITTED Lito Limpangog and DISMISSED the cases against the deceased Jerry Limpangog. The Court found the prosecution’s evidence insufficient to establish guilt beyond reasonable doubt. The testimony of Pedro Casimero, the sole eyewitness, was deemed unreliable. The Court noted serious inconsistencies in his account, including discrepancies between his sworn statement and his court testimony regarding the sequence of the stabbing incidents and his ability to identify the assailants. His claim of clear identification during a moonless night was viewed with skepticism. Furthermore, the defense of alibi, normally weak, was strengthened in this instance because it was corroborated by a barangay official and the prosecution failed to prove it was physically impossible for Lito Limpangog to have been at the crime scene. The constitutional presumption of innocence must prevail when the evidence does not establish moral certainty of guilt. The Court emphasized that the burden of proof lies with the prosecution, and any doubt must be resolved in favor of the accused.