G.R. No. 176249 - FVC Labor Union-PTGWO vs. Sama-samang Nagkakaisang Manggagawa sa FVC-SIGLO

On April 8, 1982, around 10:00–10:45 p.m. in Barangay Malaking Pook, San Pascual, Batangas, a violent encounter occurred involving the victim, Manolito Hernandez, and several parties.
Manolito, aged seventeen, was involved in a drinking spree inside his father's jeepney when an altercation arose after his father, Buenaventura Hernandez, intervened upon noticing his son’s conduct.
An altercation had already been set in motion when the victim, after insisting on going to his uncle's house despite his father’s objections, was seen by Buenaventura walking northward along the road.

Quintin Castillo y Masangkay and Ricardo Castillo y Arce were charged with murder, accused of assaulting the victim with a knife and a stone.
Evidence presented by the prosecution indicated that the accused conspired and acted in common accord with treachery and evident premeditation.
Testimonial evidence showed that after a brief struggle involving other individuals—including an encounter with Juanito Cusi—a critical moment occurred when Quintin and appellant apprehended the victim.
Eyewitness Romeo Hernandez, only thirteen at the time, observed from a distance that the assailants subdued and brutally attacked the already defenseless victim; he testified that Quintin stabbed the victim while appellant struck his head with a stone.

Multiple prosecution witnesses, including Dr. Johnny Ilustre, Francisco Castor, Francisco Bonado, and members of the victim’s family (Buenaventura, Cosme, Romeo, and Donata Hernandez), testified on various aspects of the incident.
Dr. Ilustre’s post-mortem examination confirmed that the victim sustained numerous injuries—four fatal among a total of fourteen injuries—resulting in severe cerebral hemorrhage, skull and mandible fractures.
The recovery of a stone near the scene, later identified by Romeo Hernandez as the same stone used in the attack, supported the physical evidence against the accused.

The accused (Quintin and appellant) denied the prosecution’s account by asserting that they only accompanied the victim when requested by his father and subsequently left, countering the narrative of a concerted assault.
Their version included an alternative explanation wherein they encountered three drunken men, heard the victim shout “Labas dito ang barako!”, and maintained that they did not partake in any violent assault.
Defense witnesses, including Pastor de Castro, Romulo Cusi, and the accused themselves, corroborated a version divergent from the prosecution’s testimony by emphasizing inconsistencies in the eyewitness account.

The Regional Trial Court of Batangas City, Branch 3, after a detailed assessment of the evidence and testimonies, convicted the accused of murder, accentuating treachery as an aggravating circumstance.
The accused were sentenced under the provisions of the Indeterminate Sentence Law with penalties ranging from reclusion temporal (with specified minimum and maximum terms), along with orders for indemnity and additional damages.
Both accused appealed the conviction to the Court of Appeals. The appellate court revised certain penalty provisions—modifying Quintin’s term and sentencing the appellant to reclusion perpetua—and certified the case to the Supreme Court for criminal liability review.
Subsequent procedural developments included the granting of bail (which was later abandoned by the appellant) and issues regarding the appellant’s flight, triggering concerns regarding the continuation or dismissal of his appeal.

The case presented procedural complexities such as the application of the Indeterminate Sentence Law and the interpretation of evidence from a sole eyewitness with a delayed report.
The appellant’s escape from custody (jumping bail) introduced a significant procedural issue regarding whether his appeal should be dismissed per Rules 124 and 125 of the Revised Rules of Court.
The Supreme Court reviewed assignments of error related to the weight given to the eyewitness testimony, the reliance on the prosecution’s evidence over the unsubstantiated defense claims, and the impact of the accused’s flight on the proceedings.

Whether the sole eyewitness testimony of Romeo Hernandez, despite his young age and delayed reporting, was sufficient to sustain the conviction of the accused.
Whether the trial court erred in placing undue credence in the prosecution’s evidence while completely discounting the defense’s version of events.
Whether the accused’s act of jumping bail should lead to the dismissal of his appeal, or if proceeding with review avoids rewarding evasive behavior with an unjust final judgment.
What is the proper qualification of the penalty—reclusion temporal versus reclusion perpetua—in light of the established facts, aggravating (treachery) and mitigating circumstances (such as voluntary surrender in part of the proceedings).
Whether the aggravating circumstance of abuse of superior strength should independently affect sentencing or if it is already subsumed under the element of treachery.