Case Digest (G.R. No. L-48070)
Facts:
The People of the Philippines v. Medardo Castelo y de Castro, G.R. No. L-48070, December 26, 1984, Supreme Court Second Division, Makasiar, J., writing for the Court. The plaintiff-appellee was the People of the Philippines; the defendant-appellant was Medardo Castelo y de Castro.The accused was charged by information in the Court of First Instance (CFI) of Batangas, Eighth Judicial District, Branch IV, Lipa City with murder for the September 23, 1969 killing of Ricardo Villanueva. At arraignment on March 31, 1975 the accused pleaded not guilty. After trial, the CFI rendered judgment on September 23, 1977 finding Medardo Castelo guilty beyond reasonable doubt as principal of murder with the qualifying circumstance of treachery (including nocturnity) and sentenced him to reclusion perpetua, ordered indemnity to the heirs (P12,000), and credited preventive imprisonment pursuant to Article 29, RPC as amended.
On appeal to the Supreme Court, the Office of the Solicitor General, representing the prosecution, filed a Manifestation in lieu of an appellee's brief recommending acquittal. The prosecution’s trial theory relied principally on the testimony of barrio captain Remo Madlangbayan, who in 1975 identified the Castelos as assailants; supporting pretrial statements by Dominador Sornito and Numeriano Sandro to the San Juan police (dated September 24, 1969) had implicated the accused and his brother. Sornito, however, died before trial and his sworn statement was admitted at trial; Sandro later recanted and testified for the defense, claiming coercion by police. The accused presented an alibi that he kept watch at a clinic from 7:00 p.m. to midnight, corroborated by his brother Vicente. Police testimony indicated that the investigating officers initially reported only Sornito and Sandro as eyewitnesses; Remo's written statement to the fiscal was executed more than five years after the incident and the purported letter he all...(Pro-only)
Issues:
- Did the trial court violate the accused's constitutional right to confrontation and err in relying on hearsay (the sworn statement of the deceased Dominador Sornito) and belated affidavits when convicting the accused?
- Was the prosecution’s evidence — consisting chiefly of the belated testimony of Remo Madlangbayan and the recanted statement of Numeriano Sandro — sufficient to sustain a conviction beyond reasonable doubt agains...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)