G.R. No. 217725 - Chong vs. Senate of the Philippines

This case arises from a criminal trial in the Court of First Instance of Leyte (Ormoc City) where Teofilo Cabiltes and Gonzalo Cabiltes were found guilty beyond reasonable doubt of murder.
The amended complaint originally charged seven persons with the murder of Esteban Mesias, but due to grave doubts regarding the participation of some, only Teofilo Cabiltes, Gonzalo Cabiltes, and Diego Cabiltes were ultimately indicted.

On or about May 31, 1960, during a fiesta in Natubgan, Kananga, Leyte, the accused allegedly conspired to kill Esteban Mesias in retaliation for an earlier assault on Domingo Cabiltes by Mesias.
The accused, acting in concert:

Teofilo Cabiltes initiated and planned the murder after receiving news from his uncle Gregorio about the assault on his father.
Gonzalo Cabiltes, along with other alleged co-accused, joined in the plan.

Teofilo Cabiltes changing his clothes, arming himself with a hunting knife, and later joining a group that included Domingo Cabiltes, Diego Cabiltes, Arturo Allego, Carlito Moriles, and Gualberto Nedera.
The group intercepted Mesias about half a kilometer from Domingo Cabiltes’ house as they moved towards the poblacion of Kananga.
Teofilo Cabiltes walked side by side with Mesias and stabbed him in the back with a hunting knife.
Gonzalo Cabiltes further wounded Mesias by stabbing him in the breast with a small bolo.
The deceased, after slumping to the ground, was then carried to a nearby canal where Teofilo Cabiltes hacked him further on the chin and other parts of the body.
Subsequent actions included Diego Cabiltes hastily returning home while Gonzalo Cabiltes fled to his aunt’s house before being apprehended.

Faustino Alapan, the sole eyewitness for the prosecution, provided an affidavit as well as live testimony.
In his affidavit, Alapan stated that he was in the house of Domingo Cabiltes at around six o’clock in the evening on the day of the killing.
In direct testimony, however, he mentioned being at Diego Cabiltes’ house earlier in the day, leading to a noted discrepancy regarding his whereabouts.

The record includes detailed autopsy findings showing multiple stab wounds inflicted by more than one weapon.
Two different weapons—a hunting knife and a small bolo—were introduced, corresponding to the accounts implicating both Teofilo and Gonzalo Cabiltes.

Teofilo Cabiltes’ extrajudicial confession detailed that he and his companions, including Gonzalo Cabiltes, participated in stabbing and stoning the victim.
Though extrajudicial, such confessions were admissible as corroborative evidence of the facts against co-defendants under existing jurisprudence.

The defense contested the credibility of Alapan’s testimony, arguing that the discrepancies in his affidavit and live testimony cast doubt on his reliability.
It was further argued that the inclusion of Alapan, a 15-year-old laborer with limited education, in the assault cast doubt on the coherence of the prosecution’s narrative.
The defense also maintained that statements obtained from the accused might have been the result of police maltreatment, citing advice to seek medical treatment, although no supporting medical certificates were produced.

An appeal was filed by Teofilo Cabiltes and Gonzalo Cabiltes from the decision of the Court of First Instance.
Teofilo Cabiltes later withdrew his appeal; thus, only the appeal of Gonzalo Cabiltes is considered in this decision.
The central controversy in the appeal focused on the credibility and consistency of testimony—specifically that of witness Faustino Alapan—and on whether the evidence sufficiently established the conspiracy and participation of Gonzalo Cabiltes in the murder.

Does the discrepancy in Faustino Alapan’s testimony between his affidavit and live examination undermine his credibility and reliability as an eyewitness?
Can the minor inconsistencies in his recollection be attributed to natural lapses in memory without affecting the substance of his testimony?

Is there sufficient evidence to establish that Gonzalo Cabiltes acted in concert with his co-accused in a conspiracy to commit murder?
Does the extrajudicial confession of Teofilo Cabiltes, along with other corroborative evidence, conclusively prove the participation of Gonzalo Cabiltes in the crime?

Were the affidavits and extra judicial statements obtained from the accused executed freely and voluntarily, despite claims of police maltreatment?
Do the physical evidence and autopsy findings reliably corroborate the testimony regarding the commission of the murder?

Can the inconsistencies related to the timing and location of the eyewitness’s testimony be logically resolved by considering the environmental and contextual factors surrounding the crime?