G.R. No. 227755 - People vs. Lita

The case involves the People of the Philippines charging Noel Lita and Romulo Malinis, among others, for the murder of Barangay Councilman Hipolito Rementilla.
The Information alleged that the accused conspired, conspired, and mutually assisted in the killing of Hipolito by means of treachery and evident premeditation, using unlicensed firearms.
Several co-accused were charged, including Barangay Chair Benito Moncada, Sebastian Requitud, Joselito Piliin, Benigno Obrador, Inosencio Pondano, Felicisimo Amada, and Julian Consul.

The Information detailed that on or about 12:10 a.m. on December 21, 1998, in Brgy. Paagahan, Mabitac, Laguna, the accused assembled and acted in a concerted manner:

They allegedly surrounded Hipolito’s house following a Christmas party held in Barangay Paagahan on the night of December 20, 1998.
The accused were said to have been armed with a .45 caliber pistol and a .38 revolver.

Shooting Hipolito with multiple gunshots, with fatal wounds inflicted at different parts of his body.
Infliction of wounds described as posterior entry points (indicating treachery) and additional wounds on the front that were explained post facto as possibly occurring while Hipolito was writhing.

Ma. Socorro Banyon testified that she saw Amada, Barangay Chair Moncada, and Requitud near Hipolito’s house in the afternoon of December 20, 1998.
Nonilon Rementilla, Hipolito’s nephew, provided a detailed account saying he followed Hipolito after a Christmas party and observed the sequence of shootings by Consul and Amada.
Benedicto Sayaman recounted a meeting at Barangay Chair Moncada’s residence where the conspiracy to kill Hipolito was discussed and planned.
Dr. Winston Tan’s postmortem examination documented eight entry wounds on Hipolito’s body, which generally corroborated Nonilon’s narrative despite minor discrepancies.

Malinis claimed he was asleep at home when police came looking for his brother, Lita, and another named Onyok, and he later accompanied them to the municipal hall.
Lita testified that he was watching the Christmas party and later joined his companions for a drinking session, after which he went to his nipa hut.
Other accused, such as Requitud, Piliin, and Amada, presented accounts that placed them in locations or activities (e.g., helping with party preparations, fixing lights, attending to personal errands) away from active participation in the crime.
Although denials and alibis were offered by several accused, none of these accounts were adequately corroborated by independent evidence.

The trial court gave significant credence to Nonilon’s testimony, describing it as “straightforward and categorical” despite certain inconsistencies with Dr. Tan’s postmortem findings.
The court noted that minor discrepancies in details (such as the number and placement of gunshot wounds) did not undermine the overall credibility of the eyewitness accounts.
Evidence of concerted action among the accused was derived from:

The presence of Lita, Malinis, and other co-accused at or near the crime scene while armed.
Consul’s admission to shooting Hipolito and confirming a prior meeting that established the intent to kill.

The trial court also analyzed the absence of corroborative evidence for alleged mitigating circumstances such as voluntary surrender.

In its April 10, 2013 Decision, the Regional Trial Court found Lita and Malinis guilty beyond reasonable doubt of murder, while acquitting Obrador, Requitud, and Pondano.
The trial court imposed the penalty of reclusion perpetua without eligibility for parole on Lita and Malinis, pursuant to Republic Act No. 9346, which prohibits capital punishment.
On appeal, Lita and Malinis challenged the conviction, questioning the credibility of witnesses, the existence of a conspiracy, the alleged inconsistencies in evidence, and the application of the voluntary surrender doctrine.
The Court of Appeals, in its December 10, 2015 Decision, affirmed the decision of the trial court and dismissed the alibi and denial defenses raised by the accused.
Subsequent proceedings led to the filing of a Notice of Appeal before the Supreme Court, which was ultimately disposed of by dismissing the appeal and upholding the convictions.

Whether the trial court’s findings regarding the credibility of key eyewitnesses, particularly Nonilon’s testimony, were properly sustained.
Whether the inconsistencies between Nonilon’s account of the shooting and Dr. Tan’s postmortem findings were material enough to undermine the overall evidence of murder.
Whether sufficient circumstantial evidence existed to establish the conspiracy among the accused to kill Hipolito.
Whether the accused’s alibi defenses and denials, including claims of voluntary surrender, were adequately supported by reliable evidence.
Whether the cumulative evidence established the guilt of accused-appellants Lita and Malinis beyond reasonable doubt.