G.R. No. L-48070 - People vs. Castelo y De Castro

The accused, Medardo Castelo y de Castro, was charged with the crime of murder committed on September 23, 1969, in Barrio Laiya, Municipality of San Juan, Batangas.
The killing involved the use of firearms, with the accused allegedly acting in concert with his brother, Romulo Castelo y de Castro, who was at large during the trial.
The victim, Ricardo Villanueva, sustained multiple gunshot and lacerated wounds resulting in fatal hemorrhage and shock.

The prosecution’s information described that without warning, the accused and his accomplice attacked Ricardo Villanueva, shooting him after ambushing him from behind designated landmarks (e.g., behind a stable and near a coconut tree).
The qualifying circumstances included treachery (with elements such as nocturnity and evident premeditation) which purportedly elevated the crime to murder.

Primary eyewitness testimony was given by Remo Madlangbayan, the barrio captain, who later identified the accused and his brother as the perpetrators.

Remo’s account detailed his observation of the assailants approaching the scene immediately after the fatal shots and his claim that the accused uttered “Patawarin mo ako Carding at ako’y naganti lamang.”
His statement, however, showed several inconsistencies and improbabilities, including the exact audibility of words from a distance of approximately fifteen meters amid the chaos of gunfire.

Other eyewitnesses included Dominador Sornito and Numeriano Sandro, whose statements originally implicated the accused.

Sornito’s sworn statement, despite being influential in the trial court’s findings, was later deemed inadmissible as it constituted hearsay evidence; Sornito had died before trial and was never available for cross-examination.
Sandro initially implicated the accused but then recanted his earlier written statement, testifying in favor of the accused and disclosing that his original statement was extracted under coercion.

The accused invoked an alibi, asserting that on the night of the incident he was at Dr. Ona’s clinic, looking after his sick brother Vicente Castelo from 7:00 p.m. to midnight.

Inconsistencies also emerged regarding a “letter” allegedly sent by Remo Madlangbayan to the Chief of Police of San Juan, Batangas, which purportedly reported the ambush.

Testimonies from the investigating officers, including that of Patrolman Teofilo Sacristan and Chief Peradilla, revealed that the letter contained only a report of the ambush without identifying the perpetrators.
No physical copy of the letter was ever produced in court, and its contents became a point of contention.

The investigation immediately after the crime indicated that the only reliable eyewitnesses were Sornito and Sandro, with police accounts confirming their exclusive role in the initial report.
The trial court, however, gave undue weight to the later testimony of Remo Madlangbayan despite his delayed account—over five years after the killing—and his evident bias rooted in a longstanding grudge against the accused.
The trial court’s acceptance of Sornito’s hearsay statement, in the absence of his live testimony, was identified as a violation of the accused’s constitutional right to confrontation.

Whether the conviction of the accused was based on positive, independent evidence or merely on the weakness of the defense’s alibi.
Whether the reliance on the delayed and inconsistent testimony of Remo Madlangbayan satisfied the standard of proving guilt beyond reasonable doubt.

Whether the trial court erred in admitting hearsay evidence (specifically, the sworn statement of the deceased eyewitness, Dominador Sornito) against the accused.
Whether the selective use of testimonial evidence, without giving the accused the opportunity to properly cross-examine such witnesses, violated the constitutional right of confrontation as guaranteed by Section 19, Article IV of the 1973 Constitution.

Whether the court properly evaluated the defense’s alibi, which was corroborated by the accused’s brother, against the prosecution’s narrative.
Whether the failure of the prosecution to substantiate its evidence with credible, consistent, and timely eyewitness accounts warranted a reversal of the conviction.