G.R. No. L-1804 - People vs. Vergara

The defendant, Maximo Vergara, was charged with robbery with homicide for the killing of Amando de los Santos on June 27, 1943, in Calabanga, Camarines Sur.
A co-accused, Macario Vergara, was also charged under the same information but was acquitted by the trial court.
The crime involved not only the killing of Amando but also the robbery of various household belongings (including rice, palay, jewelry, and a wristwatch) from the victim’s residence.

Dolores Galicia, the common-law wife of the victim, provided a detailed account:

She described being at home when a voice called for her husband.
On answering, Amando was pushed, tied up, and later led outside under orders.
The assailants, identified by name as Maximo and Macario Vergara, used a bolo and a dagger respectively to attack and kill Amando.
Despite it being a moonless and dark night, she claimed to have seen distinct details such as the wound at the base of the neck and on the chest.

Additional eyewitnesses such as Felipe de Leon, Margarito Mecate, and others corroborated parts of her account:

They testified to similar events where the victims were tied up, robbed, and moved to a secluded area where the killing took place.
Their testimonies included descriptions of the assailants’ actions, the timing of the events, and the subsequent discovery of the body with visible wounds.

Conflicting details emerged regarding the identity and recognition of the attackers:

Some witnesses expressed difficulty in positively identifying one of the accused, particularly Macario Vergara, due to the circumstances of darkness and emotional distress.
Testimonies varied with respect to the exact moment and place of the crime, creating inconsistencies in the accounts offered.

Evidence was presented showing that on a later date (July 14, 1946), Dolores Galicia, along with Felipe de Leon, had an encounter with Maximo Vergara over a land dispute involving coconut gathering.
Background issues involving land litigation and personal grudges were evident:

Disputes between Dolores Galicia and parties associated with Maximo Vergara (including conflicts with Benita Apolonio, the mortgagor, and other neighbors) raised questions about the motive behind the criminal complaint.
Prior litigious interactions, including actions of assault and counterclaims between the Garza family and the Vergaras, were documented.

The alleged crime occurred in 1943, yet the formal complaint was delayed until after the Japanese occupation ended, raising issues on the persistence or reliability of testimony.

Macario Vergara claimed an alibi, asserting he was detained in Camp Bongabong, Nueva Ecija as a prisoner of the Japanese during the time of the incident.
Several defense witnesses testified that, contrary to the prosecution’s narrative, Maximo Vergara was engaged elsewhere:

His duty as the leader of the local Ronda organization positioned him far from the scene during the time the crime allegedly occurred.
This occupational duty was corroborated by testimonies from multiple Ronda members and local officials.

Rebuttal witnesses for the prosecution attempted to challenge the defense accounts, yet their own descriptions of the incident showcased inconsistencies, particularly about light conditions and the ability to recognize critical details.

Whether the detailed yet inconsistent testimonies (especially those given by Dolores Galicia and her cohorts) can reliably identify Maximo Vergara as the perpetrator.
Whether the alleged visual acuity of the witnesses in a moonless, dark setting is plausible given the circumstances described.

The extent to which the identification of Maximo Vergara by the prosecution witnesses is tainted by possible sensory error or emotional distress.
Whether the defense evidence, particularly the alibi provided by Macario Vergara and corroborated by the Ronda duty records, establishes that Maximo Vergara could not have participated in the crime.

Whether the longstanding personal and land-related disputes contributed to the decision to prosecute, rather than a genuine criminal motive.
How the delay between the incident (June 27, 1943) and the filing of the complaint (post-liberation) impacts the credibility of the prosecution’s case.

Can the inconsistencies in the testimony regarding one accused (Macario Vergara) be logically extended to discredit the identification of Maximo Vergara in a joint criminal undertaking?