G.R. No. 128321 - People vs. Canete

The incident arose from longstanding animosity between student groups at the Central Colleges of the Philippines (CCP).
Members of the APO and Samahang Ilocano fraternities, who were friendly with one another, were at odds with the members of the TAU Gamma Phi fraternity.
An earlier altercation occurred in August or September 1993 when a member of APO threw a pillbox at a TAU Gamma member.

Around 9:30 p.m., Manolito U. Manuyag, Jr. and Fernando Obrino, students and members of TAU Gamma, were near a Jollibee Restaurant and Uniwide Store at Cubao, Quezon City.
Upon noticing Cynthia Pajarillo, a member of APO, Fernando was alerted by his companion Manolito.
A group of APO members—Frank Faisal, Troy Malate, Roldan Miranda, and the appellant Enrique aRickya CaAete—converged on Fernando.
The assailants were armed with knives and pieces of wood. The appellant struck Fernando with a piece of wood and stabbed him, and his companions also participated in the assault.
Fernando sustained multiple stab wounds and a fatal blow, fell to the ground, and later died at St. Luke’s Hospital.

Mario Sillar, a construction worker, witnessed a violent encounter near the scene, reporting a “rambulan” involving six persons mauling an individual.
Sillar described the incident in detail, noting that one of the maulers (described as tall with long hair and a heavy build) boxed the victim twice.
Other bystanders and survivors (e.g., Manolito) provided identifications such as pointing out Troy Malate and Roldan Miranda during a police lineup.
Testimonies were conflicting: while some witnesses identified individuals through photographs and descriptive evidence, others questioned their proximity and observations during the commotion.

Stab wounds on the anterior right upper thorax (through the 4th right intercostal space), anterior left lower thorax (piercing the pericardium and left ventricle), right deltopectoral and axillary regions, left supra-scapular region, and multiple wounds on the posterior body regions and limbs.
Incised and linear abrasion injuries suggesting the use of pointed and bladed instruments.

The doctor singled out specific wounds as fatal (wounds nos. 1, 2, and 4), based on their depth and location.
Physical evidence established that the victim died from multiple stab wounds, with no signs of blunt trauma such as contusions or hematomas.

The Regional Trial Court (RTC) of Quezon City, Branch 95, charged and convicted the appellant Enrique aRickya CaAete of murder, sentencing him to reclusion perpetua.
The charge alleged that the accused, along with his companions, conspired and attacked Fernando with superior strength and treachery.
While the appellant was convicted, co-accused Elmer Alipio was later acquitted for lack of sufficient evidence.
The prosecution primarily relied on the testimony of eyewitness Sillar and the medico-legal report to establish the elements of murder.

The appellant denied the charge, asserting an alibi by claiming documented attendance at a special assembly and involvement in unrelated activities on the day of the incident.
He argued that Manuyag’s testimony against him stemmed from personal animosity due to a previous altercation that led to Manuyag’s expulsion from CCP.
The defense maintained that the evidence, particularly Sillar’s testimony, was unreliable and conflicted with the physical findings of the victim’s injuries.

On appeal, the appellant contended that the prosecution failed to prove his guilt beyond reasonable doubt.
He argued that the testimony of Sillar was inherently unreliable due to inconsistencies, such as his failure to notice any weaponry during the prolonged mauling and the discrepancies regarding the nature of the victim’s injuries.
The appellant also questioned the imposition of qualifying circumstances—treachery and abuse of superior strength—asserting that the physical evidence did not support these aggravating factors.
Emphasis was placed on the constitutional presumption of innocence and the necessity of the prosecution’s proof overcoming reasonable doubt.

Whether the prosecution proved beyond reasonable doubt that the appellant Enrique aRickya CaAete was guilty of murder as defined by Article 248 of the Revised Penal Code.
Whether the defense of alibi presented by the appellant was sufficient, particularly in the face of identification evidence by witness Sillar.
Whether the trial court erringly applied the aggravating circumstances of treachery and abuse of superior strength in aggravating the crime.
Whether the constitutional presumption of innocence was duly observed throughout the trial proceedings.
Whether the reliance on Sillar’s testimony, despite its inconsistencies with the physical evidence, was justifiable in convicting the appellant.