PEOPLE OF THE PHILIPPINES vs.

ANGELO ARCEO y MALI cloud of doubt if their declarations tallied in their minutest details, for
G.R. No. 88324. July 6, 1990. then, that would not be natural. That would indicate that the
Petitioner: People of the Philippines testimonies were rehearsed.
Respondent: Angelo Arceo As to Limpin’s involvement in a stabbing incident: in order to affect
Cause of Action: Robbery With Homicide the credibility of a witness by the mere fact that he was charged with
(OCA circular 101-2017 Section 11-13) an offense, previous conviction by final judgment is required, and the
existence of a pending information may not be shown to impeach the
witness. With more reason, therefore, should Limpin not be
discredited merely on the basis of a complaint filed with the city
FACTS: RTC rendered decision finding Arceo guilty of robbery with fiscal, there being no showing that an information has been filed in
homicide against the victim Delfin Manalese. Evidence for court and that judgment has been rendered convicting him of the
prosecution included the testimony of Caladiao, a market porter. He offense.
said that on the night of the incident, he was on his way to work and
he saw Delfin standing and two persons approached him, forced to
get his watch and then stabbed him. He recognized Arceo and Ramil
Cecilio. He knows them because he sees them loitering around the
area.
Reynaldo Limpin was also one of those who testified. He said that on
the night of the incident, he heard shouts of “magnanakaw!” he then
moved towards the direction of the commotion and noticed two
persons running in a hurry one of them holding a bladed weapon
with traces of blood.
Arceo now assails the credibility of these witnesses. As to Caladiao,
he neither helped the victim nor could he have identified the
perpetrators because the place was crowded and it was impossible
to identify them. As to Limpin, there was some inconsistencies
because he heard shouts of “magnanakaw” while Caladiao never
testified to the same. Also, Limpin was implicated on another
stabbing incident thereby casting doubt on his credibility.

ISSUE: W/N Caladiao and Limpin are credible witnesses.

HELD: YES. Inconsistencies referring to minor details do not destroy

the credibility of witnesses. From an analysis of the testimony of the
witnesses for the prosecution, it becomes readily apparent that the
supposed errors involve minor matters which have no material
bearing on the commission of the criminal act itself. Variances can
be attributed to the fact that different persons have diverse
impressions and perceptions of a startling event. On the other hand,
the testimonies of two or more witnesses would be under a serious