Case Digest (G.R. No. 232189)
Facts:
People of the Philippines v. Valentino Gamiao y de Jesus and Rolando Caoile y Bautista, G.R. No. 91492, January 19, 1995, Supreme Court Second Division, Regalado, J., writing for the Court.
The prosecution charged Rolando Caoile and Valentino Gamiao with murder attended by evident premeditation and treachery for the stabbing death of Eulogio Armas on August 17, 1982. After arraignment the accused pleaded not guilty. The Regional Trial Court (Manila, Branch XL) tried the case, found both guilty of murder qualified by treachery, sentenced them to reclusion perpetua, ordered payment of P30,000.00 death indemnity and P33,000.00 consequential damages to the heirs, and costs. Gamiao absconded during the proceedings; his bail was cancelled and a warrant issued, but he remained at large. The trial court had consolidated another related criminal case but proceeded only with the instant case because some accused were not in custody.
The prosecution’s narrative, supported by eyewitnesses (classmates who were near the locus), described a group of Samahang Ilokano members suddenly drawing balisong knives and surrounding the victims; Gamiao allegedly first stabbed Armas and Caoile repeatedly joined in, with several assailants taking turns. Armas sustained six stab wounds and died; witnesses later identified Gamiao and Caoile, and some informed police leading to Gamiao’s immediate arrest.
Appellant Caoile asserted an alibi: he had stopped schooling in March 1981, worked for Abrigo Trading in Dinalupihan, Bataan, and on August 17, 1982 was at the company and at Paragon Paper Mills between 5:30–8:00 P.M., which he claimed made it impossible for him to be at the 2:00 P.M. killing in Manila. He presented photocopies of a residence tax certificate, a Daily Visitor’s Log Book entry, and a certification of employment. The trial court disbelieved the alibi and the documentary proofs, noting discrepancies and that originals were not produced; it also found identification testimony credible. Caoile appealed the conviction to the Supreme Court seeking reversal on grounds that his alibi was improperly rejected and that the conviction rested on incomplete stenographic transcripts.
During review it emerged that stenographic notes for the testimonies of Dr. Mariano Cuevas (autopsy) and Pat. Solomon Bataller (taking sworn statements) were missing because the stenographers failed to turn over their notes; the Office of the Court Administrator recommended...(Pro-only)
Issues:
- Was the trial court’s finding of credibility in the prosecution witnesses and rejection of appellant Caoile’s alibi entitled to be disturbed?
- Did the absence of stenographic notes of two prosecution witnesses render the trial court’s judgment invalid or require retaking of testimony as a condition to review?
- Was treachery proved so as to support the qualifying circumstance...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)