Title
People vs. Lavapie
Case
G.R. No. 130209
Decision Date
Mar 14, 2001
Accused acquitted of murder due to inconsistent testimonies, insufficient evidence, and failure to prove guilt beyond reasonable doubt.

Case Summary (G.R. No. L-52819)

Factual Background

On October 17, 1989, Larry Lavapie and Rey San Pascual pleaded not guilty during their arraignment. Other accused—Benigno Catina Jr., Santos San Pascual Jr., Rey San Pascual, and Simeon Lachano—also entered pleas of not guilty on subsequent dates. The prosecution presented several witnesses, including Domingo Samonte and Jenny Cordial, who provided testimonies regarding the events leading to Sonny Sierva's death. The prosecution's narrative details how the victim was ambushed and subsequently hacked with a bolo, resulting in fatal injuries.

Evidence Presented

Key eyewitness Domingo Samonte testified that he saw Santos San Pascual, Sr. holding Sonny Sierva's hands behind his back while Larry Lavapie hacked him on the neck with a bolo. After witnessing the attack, Samonte fled the scene. Additional eyewitness testimony came from Jenny Cordial and Enrico Sierva, who, having arrived shortly after the incident, identified the victim and saw the accused-appellants near the crime scene. Dr. Alicia Mercurio provided the autopsy report, detailing the severe injuries that resulted in Sierva's death, thereby corroborating the witness accounts.

Defense Testimonies

The defense primarily rested on alibi and denial claims, asserting that the accused-appellants were at a dance during the time of the incident. Lavapie and Santos San Pascual, Jr. testified that they left the dance hall together and had stayed at a friend's barn, thus establishing their whereabouts during the crime. Other defense witnesses supported their alibis, arguing against the testimonies of the prosecution and contending that they lacked credibility.

Trial Court's Decision

The trial court ruled that the evidence presented against Larry Lavapie and Santos San Pascual, Sr. was substantial, leading to their conviction for murder, qualified by treachery. The court highlighted the conspiracy among the accused given their familial relationship and joint actions against the victim. In sentencing, the court imposed reclusion perpetua, ordered indemnities to the victim's heirs, and acquitted the remaining accused for insufficient evidence.

Appeal and Appellate Court's Analysis

The case was later appealed, focusing on the assertion that the testimonies of key prosecution witnesses had been retracted. The appellate court noted inconsistencies between the testimony of Samonte and the physical evidence, particularly regarding the location of injuries sustained by Sierva. This discrepancy raised reasonable doubt about the reliability of Samonte's identification of Lavapie as the attacker.

The court em

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