Case Summary (G.R. No. 141438-40)
Charges and Decisions
The RTC convicted Lito and Jerry Limpangog of murder and frustrated murder as follows: for Criminal Case No. 4375 a conviction for frustrated murder; Criminal Case No. 4376 resulted in a conviction for murder; and Criminal Case No. 4393 resulted in another conviction for frustrated murder. The sentences included varying periods of imprisonment and monetary indemnities to the victims’ families.
Prosecution's Case
The prosecution established that on the night of November 19, 1993, the Limpangogs hired a motorcab driven by Pedro Casimero to go to Isabel, Leyte, where they subsequently attacked him and his passengers, inflicting serious injuries and resulting in the death of Jose Cabanero. Witness testimonies, primarily from Pedro and Reny Boy Casimero, described the events leading up to and following the attacks.
Defense's Version
The appellants contested their identification as the assailants, claiming an absence of conclusive evidence against them. They claimed that during an identification session, Pedro Casimero failed to recognize them, which they argued undermined the prosecution's case.
Court's Evaluation of Evidence
The RTC found the testimonies of the prosecution witnesses credible, as they had directly interacted with the assailants prior to the attack. The court noted the presence of a distinctive tattoo on Lito Limpangog's left hand, which allegedly aided witnesses in identifying him.
Legal Principles: Burden of Proof
In criminal prosecution, the State bears the burden of proving the accused's guilt beyond a reasonable doubt. The constitutional presumption of innocence must be upheld until the prosecution meets this burden with compelling evidence against the accused.
Analysis of Identification
Upon appeal, it was highlighted that identification in this case was problematic. Key witness Pedro Casimero had initially failed to identify the Limpangogs as his assailants during police investigations. The trial court’s reliance on his later in-court identification, given the considerable time lapse and his prior inconsistent statements, was analyzed critically.
Court's Reversal and Acquittal
The Supreme Court ultimately found that the prosecution could not establish with certainty that Lito Limpangog was one of the assailants. The Court scrutinized the identification process and concluded that the inconsistencies voided the prosecution's claims of beyond a reasona
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Statement of the Case
- Lito and Jerry Limpangog appeal the Joint Decision of the Regional Trial Court (RTC) of Ormoc City, which convicted them of murder and two counts of frustrated murder.
- The RTC's decision, dated September 15, 1994, includes sentences of:
- Ten (10) years of prision mayor to seventeen (17) years of reclusion temporal for Criminal Case No. 4375-0 (Frustrated Murder).
- Reclusion perpetua for Criminal Case No. 4376-0 (Murder).
- Ten (10) years of prision mayor to seventeen (17) years of reclusion temporal for Criminal Case No. 4393-0 (Frustrated Murder).
- The appellants were also ordered to indemnify the victims' heirs.
Facts
- The appellants were charged with crimes that occurred on November 19, 1993, involving attacks on Pedro Casimero, Reny Boy Casimero, and Jose Cabanero.
- Specific details of the attacks include:
- Criminal Case No. 4375-0: Reny Boy Casimero was stabbed multiple times but survived due to medical intervention.
- Criminal Case No. 4376-0: Jose Cabanero sustained fatal stab wounds leading to his death.
- Criminal Case No. 4393-0: Pedro Casimero was also attacked but survived.
- Eyewitness accounts include testimonies from Pedro Casimero and Reny Boy Casimero, detailing their experiences during the incident.