GR 210802; (August, 2017) (Digest)

G.R. No. 210802. August 09, 2017.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. RENE BOY DIMAPILIT Y ABELLADO, ACCUSED-APPELLANT.

FACTS

On February 11, 2007, Diego Garcia went to the house of Pastor Dimapilit to discuss renting his tricycle. When he did not return promptly, his live-in partner, Magdalena Apasan, and his brother, Simeon Garcia, went to look for him. Upon approaching the house, they witnessed Pastor and his sons, including accused-appellant Rene Boy Dimapilit, assaulting Diego. Magdalena testified that she saw Junnel Dimapilit box Diego, Pastor hit him with a piece of wood, and Rene Boy strike his face with a crowbar. When Simeon shouted for them to stop, Rene Boy threatened him. Magdalena hid, and Simeon ran for help. Diego was found dead with severe injuries, including a fatal hacking wound and a depressed skull fracture.
Rene Boy, along with his father and brothers, was charged with Murder. Only Rene Boy was arraigned after the others escaped detention. The Regional Trial Court convicted him, a decision affirmed by the Court of Appeals. Rene Boy appealed, challenging Magdalena’s credibility due to inconsistencies between her court testimony and her sworn statement regarding which brother pursued Diego and the presence of Simeon.

ISSUE

Whether the inconsistencies in the testimony of the eyewitness, Magdalena Apasan, are sufficient to reverse the conviction of accused-appellant Rene Boy Dimapilit for Murder.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court held that inconsistencies on minor details, which do not relate to the central fact of the crime, do not impair a witness’s credibility. Magdalena’s variance on whether it was Junnel or Joel who chased Diego, and her initial omission of Simeon’s presence in her sworn statement, were deemed minor. These did not pertain to the essential elements of the crime—the identity of the principal assailant and the occurrence of the killing. The Court emphasized that her clear, positive, and consistent narration of the central incident—seeing Rene Boy strike the victim with a crowbar—remained unrebutted. Witnesses are not expected to recall every minute detail with perfect consistency, especially under traumatic circumstances. The core of her testimony identifying Rene Boy as a direct participant was credible and corroborated by the medico-legal findings on the victim’s wounds. Thus, the minor inconsistencies did not constitute a ground for reversal, as they did not create reasonable doubt regarding Rene Boy’s guilt. The qualifying circumstance of abuse of superior strength was correctly appreciated, as the attack by multiple armed assailants against an unarmed victim was clearly established.