G.R. No. 179382 - Spouses Mamaril vs. Boy Scouts of the Philippines

Petitioner Nestor B. Decasa was indicted in an Information charging him with homicide under Article 249 of the Revised Penal Code.
The alleged crime occurred on or about August 29, 1992, in the municipality of Bilar, Bohol, where petitioner is accused of using a sharp-edged/pointed weapon (comparable to a bolo) to hack Teodoro Luzano, resulting in fatal injuries to vital parts of the victim’s body.
Petitioner pleaded “Not Guilty” when arraigned on December 22, 1992.

The trial initially commenced at RTC, Branch 4, Tagbilaran City and was later re-raffled to RTC, Branch 50, Loay, Bohol after Judge Melicor inhibited himself.
During the trial, the prosecution presented key evidence primarily through eyewitness testimonies, notably that of Rogelio Boco.

Rogelio Boco provided an affidavit and later testified in open court that he witnessed petitioner hacking Teodoro at a distance of about five (5) meters under moonlit conditions.
Additional prosecution evidence included testimonies of Dr. Maria Tumanda (whose post-mortem findings confirmed multiple injuries consistent with a sharp instrument), Francisca Boco, Alona, Josefina, and Fermin.

The physical evidence, particularly the post-mortem report and death certificate, detailed that the cause of death was hypovolemic shock secondary to hemorrhage from multiple wounds, emphasizing injuries to the head, chest, and extremities.

He testified that he was at home with his wife and parents-in-law during the time of the offense, engaged in routine activities such as dinner, praying, and subsequently sleeping.
His alibi claimed that at no point during the night of August 29, 1992, did he leave the safety of his bedroom to commit the crime.

Additional defense witnesses echoed that there was no prior quarrel significant enough to result in homicide and that any alleged conflict with Teodoro over water sources was either misrepresented or settled previously.
Petitioner challenged the credibility of prosecution evidence, particularly pointing out:

Inconsistencies in Rogelio’s affidavit and courtroom testimony, such as the absence of a clear statement that he personally witnessed the hacking in his written statement.
Discrepancies regarding the environmental details (e.g., the phase of the moon and the timing of tuba gathering) to argue that the eyewitness account was unreliable.

The RTC rendered its Decision on August 21, 1998, convicting petitioner of homicide based on the overall corroborative evidence presented by the prosecution.
The RTC gave substantial weight to the consistent narrative provided by the eyewitnesses, especially Rogelio Boco’s testimony, despite minor inconsistencies between his affidavit and his trial testimony.
The Court of Appeals (CA) later affirmed the RTC Decision with modification on April 26, 2005, particularly adjusting the sentence under the Indeterminate Sentence Law.
The modification set the imprisonment penalty at a range between a minimum of six years and one day and a maximum of fourteen years, eight months, and one day.
A Motion for Reconsideration filed by the petitioner was denied by the CA in a Resolution dated February 23, 2006.

Petitioner argued that the RTC and the CA erred by convicting him beyond reasonable doubt given the alleged inconsistencies in the prosecution’s evidence.
He contended that the constitutional presumption of innocence was not overcome by the evidence presented.
The petitioner further asserted that judicial bias was evident, noting that Judge Calibo, who rendered the decision, did not hear all the prosecution evidence firsthand and had prior associations with the fiscal and heated exchanges with defense counsel.
He maintained that the defense evidence on alibi was sufficient to create grave doubts as to his presence at the scene and that the discrepancies in eyewitness testimony should have led to his acquittal.

Whether the trial court and the Court of Appeals erred in convicting petitioner beyond reasonable doubt despite the alleged inconsistencies in the prosecution’s evidence.

The main issue centered on the credibility and completeness of Rogelio Boco’s testimony, both his written affidavit and his live courtroom account.

Whether sufficient evidence exists to overcome the constitutional presumption of the petitioner’s innocence.

The issue involves whether the collective and corroborative evidence, notwithstanding minor discrepancies, established the petitioner's presence and active participation in the crime.

Whether the defense of alibi and denial was adequately considered and whether it created a reasonable doubt as to the petitioner's involvement.

Particularly, whether the proximity of his residence to the crime scene invalidated his claim of being confined at home during the incident.

Whether the assignment of Judge Calibo, who did not personally hear the entire testimony, compromised the trial's integrity and witness credibility assessment.

The issue examines whether reliance on transcripts and stenographic records, supplemented by an ocular inspection, is constitutionally sufficient.