GR L 18010; (September, 1968) (Digest)
G.R. No. L-18010 September 25, 1968
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TEOFILO CABILTES, ET AL., defendants-appellants.
FACTS
Teofilo Cabiltes, Gonzalo Cabiltes, and Diego Cabiltes were charged with the murder of Esteban Mesias. The information alleged that on or about May 31, 1960, they conspired and mutually helped one another, and with treachery, assaulted and wounded Mesias with a bolo, knives, and stones, inflicting fatal injuries. The prosecution’s version, primarily through eyewitness Faustino Alapan, was that during a barrio fiesta, Teofilo Cabiltes, upon learning his father Domingo had been assaulted by Mesias, proposed revenge. This proposal was assented to by Gonzalo Cabiltes, Diego Cabiltes, and others. The group, including Alapan, later overtook Mesias on the road. Teofilo stabbed Mesias in the back, and Gonzalo stabbed him in the breast. When the victim slumped, they carried him to a canal, where Teofilo further hacked him. The accused, after arrest, executed affidavits confessing to the crime. The defense claimed the affidavits were extracted through force and violence. Gonzalo Cabiltes, while admitting he was with Teofilo, denied knowledge of any plot, claiming Mesias boxed Teofilo first, prompting him (Gonzalo) to flee. The trial court found Teofilo and Gonzalo guilty of murder and sentenced them to reclusión perpetua. Teofilo withdrew his appeal, and Diego was acquitted by the trial court. Only Gonzalo Cabiltes appealed.
ISSUE
The primary issue is the credibility of prosecution eyewitness Faustino Alapan, specifically whether his testimony is rendered unreliable by alleged inconsistencies and contradictions regarding his whereabouts at the time of the killing, and consequently, whether the guilt of appellant Gonzalo Cabiltes was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the judgment of the trial court, finding Gonzalo Cabiltes guilty of murder. The Court held that the alleged inconsistencies in Alapan’s testimony were not material and did not destroy his credibility. The discrepancy between his affidavit (placing him at Domingo Cabiltes’s house) and his oral testimony (placing him at Diego Cabiltes’s house earlier that afternoon) did not preclude his presence at the scene, as the barrios were within the same municipality. His clarification that he moved to Javier Porras’s house after the killing resolved any doubt. The Court noted Alapan was a young, illiterate laborer, and minor inaccuracies were understandable. His testimony was corroborated by the extrajudicial confession of his co-accused Teofilo Cabiltes, which, while admissible only against the declarant, served as corroborative evidence of other facts establishing guilt, especially since conspiracy was proven. The claim that the confessions were coerced was rejected for lack of proof of motive by the investigating officer and the failure to present medical certificates or witnesses to support the allegation of maltreatment. The appellant’s conduct indicated he acted in concert with his co-accused.
