G.R. No. L-48746 - People vs. Cabanlig

The case involves the People of the Philippines as plaintiff-appellee and Arnold Realin as accused-appellant, with his brothers Nelson and Edwin Realin also charged.
The proceedings originated in the Regional Trial Court (RTC) of Tagudin, Ilocos Sur, Branch 25, in Criminal Case No. 348-T.
The information filed on October 31, 1989, charged the accused with the killing of James [Leiza].

On or about June 11, 1988, in Cervantes, Ilocos Sur, during a drinking session at the house of James [Leiza], an altercation ensued among the guests.
Allegedly, following disputes and challenges among the group, Arnold Realin, accompanied by companions, returned to James’s house and, using an ax-like instrument, struck the victim.
The fatal assault inflicted mortal wounds on James, leading to his death.
The incident was characterized by allegations of conspiracy, mutual complicity, treachery, and evident premeditation.

Angeles de la Cruz – testified she witnessed the assault from a vantage near a canal, observed ARNOLD swinging an ax-like instrument, and heard a remark indicating “That is your end.”
Perlita Candelario – a relative of the victim who testified that she saw ARNOLD enter James’s house and later saw him wielding the weapon; she expressed fear due to ARNOLD’s usual possession of a gun.
Mauro Sison, Jr. – provided details of the drinking session, the ensuing quarrel, and later observed ARNOLD with his companions near the scene.
Barangay Captain Ricardo Alvister, Police Investigator Prudencio Garcia, and Dr. Gaudencio Bustillo – contributed evidence regarding the sequence of events, recovery of the ax-like instrument from a canal, and autopsy findings.

Tony Rapisura and Mateo Abaya – testified to discredit certain aspects of Angeles de la Cruz’s account by stating that she did not leave her house during the mahjong session.
Donald Abaya and Arnold’s wife, Cecilia Realin – provided testimony supporting ARNOLD’s alibi and character, asserting that ARNOLD was at home or otherwise engaged at the crucial times.

Physical evidence included the recovered ax-like instrument, which was wiped of bloodstains, and the autopsy report on James’s cadaver.

At arraignment, ARNOLD and his brother Nelson pleaded not guilty while Edwin remained at large.
During the trial, the prosecution relied heavily on the identification of ARNOLD by two key eyewitnesses, despite noted minor discrepancies and delays in their statements.
ARNOLD offered an alibi claiming he was on duty at the hospital earlier in the day and later was asleep at home when the incident occurred.
The trial court initially convicted ARNOLD of murder, noting evident premeditation and treachery, and imposed reclusion perpetua along with awards of damages.

After the conviction, ARNOLD appealed and moved for reconsideration by contesting the sufficiency of evidence to sustain a murder conviction.
ARNOLD argued that the testimony of eyewitnesses—many of whom were relatives of the victim—was biased and that their inconsistencies undermined their credibility.
He further contended that his alibi should exonerate him, and claimed entitlement to a mitigating circumstance of voluntary surrender, which he argued was not properly considered by the trial court.

Was the evidence, particularly the eyewitness testimony, sufficient to prove ARNOLD’s guilt beyond reasonable doubt?
Do the blood relationships between the eyewitnesses and the victim taint their credibility?

Did the trial court err in finding evident premeditation and treachery as qualifying circumstances for murder?
Were the necessary requisites for premeditation clearly established by the evidence?

Was ARNOLD’s defense of alibi, claiming he was elsewhere at the time of the crime, credible and sufficiently corroborated?

Given the evidence, is the reduction from a murder conviction to a homicide conviction justified?
Is the imposed indeterminate penalty—ranging from 10 years to 17 years and 4 months of reclusion temporal—proper under the circumstances?