G.R. No. 112968 - People vs. Letigio

On the dawn of May 23, 1989, at Barangay Don Andres Soriano (DAS), Toledo City, an Information was filed charging Arsenio Letigio, Teddy Nemenzo, and Amay Ravanes with the murder of Jimmy Repunte.
The prosecution alleged that the accused, armed with firearms and a knife, conspired to kill Jimmy with evident premeditation, treachery, and abuse of superior strength.
It was further alleged that the crime was committed during the night—a circumstance purposefully sought by the perpetrators to facilitate the killing.

May 22, 1989 was celebrated as the barangay fiesta in DASUNA, Toledo City.
The Repunte family, including the 26-year-old victim Jimmy, had gathered for a family reunion for supper at the family home.
Later that evening, Felix Repunte, Jr., aged 24, went to his own home located about 50 meters uphill, and soon after went to bed.

Felix Repunte was awakened by the sounds of plates dropping, followed by his brother Jimmy calling for help; Jimmy was being chased by three men.
From his window, Felix observed Letigio, Ravanes, and Nemenzo “looking for something” near the family residence.
As Jimmy attempted to escape towards the family home, the assailants overtook him near the school close to the house and attacked him.
The attack involved Letigio shooting Jimmy—first causing him to fall—and then again shooting him. Subsequently, Ravanes hacked and stabbed Jimmy’s neck, causing instantaneous death.

Felix Repunte witnessed the incident from a distance of about 10 meters under the illumination of an electric bulb, noting details such as the use of a “Frontier” revolver by Letigio and .38 caliber revolvers by Nemenzo and Ravanes.
Pedro Taneo, a neighbor, while returning home, heard a gun burst at around midnight and, after seeking cover, observed from about 15 meters the three armed men and identified them as Letigio, Nemenzo, and Ravanes.

Dr. Jesus P. Cerna, a medico-legal officer, conducted the autopsy and concluded that Jimmy Repunte suffered multiple gunshot wounds and a hack wound on the chin, affirming that at least one gunshot was from a .38 caliber revolver.
Despite a discrepancy regarding the type of firearm (the “Frontier” revolver alleged to be used by Letigio versus the .38 caliber evidence), the possibility that certain wounds may have been inflicted by either weapon was not discounted.

Only Arsenio Letigio was arrested; Nemenzo and Ravanes remained at large, with the case against them archived pending their arrest.
At arraignment, Letigio pleaded not guilty; however, subsequent testimony from several witnesses, including those from the prosecution, placed him at or near the scene during the commission of the crime.
On September 6, 1993, the trial court convicted Letigio of murder, imposing reclusion perpetua and ordering the payment of civil indemnity amounting to P50,000.00.
Appellant Letigio later filed an appeal challenging the findings on several grounds.

Pedro Taneo testified about his immediate reaction after hearing gunshots—seeking cover yet observing the three armed men and confidently identifying them as his neighbors.
Felix Repunte, Jr. provided detailed observations of the sequence of events, including the distance from which he witnessed Letigio's actions, and the subsequent fatal assault on his brother.

The defense, through testimony by Rodolfo Ginos and others, presented an alternative narrative. Ginos testified that he was at Letigio’s house for a birthday celebration and later followed Letigio and his wife when they went out on the night of the incident.
Ginos and Cristita Letigio (Letigio’s wife) affirmed that they accompanied Letigio but only to advise against any rash action by Nemenzo and Ravanes.
There were minor discrepancies noted such as the description of appellant’s attire and the sequence of events; however, these were deemed trivial by the trial court.

Appellant admitted his proximity (within a 25-meter radius) to the scene, which raised doubts regarding his claim of being merely an advisor to his co-accused.
The testimonies highlighted that while the usual instinct might be to hide after hearing a gunshot, some persons (like Taneo) managed to observe and later identify the assailants.
The inconsistencies in witness recollections were confined to peripheral matters such as exact appearance or precise distances, which did not substantially alter the identification of Letigio as one of the active participants.

Whether the identification of appellant as one of the perpetrators by prosecution witnesses (Taneo and Felix Repunte, Jr.) was reliable given the circumstances, including the varied reactions to the gunshot (hiding immediately versus vigilant observation).
The effect of minor inconsistencies in the testimonies (e.g., description of attire, eyewitness positions) on the overall credibility of the witnesses.

Whether the appellate court should disturb the trial court’s findings on the credibility of the witnesses when the discrepancies revolve around collateral details rather than the material point of the crime.

Whether the defense’s contention that material facts were overlooked or ignored by the trial court (such as the supposed incongruence over the type of firearm used) is sufficient to create reasonable doubt.
Whether the defense’s invocation of the maxim "falsus in unus, falsus in omnibus" is applicable given the corroborative elements present in the prosecution’s evidence.