G.R. No. 143819 - People vs. Cuenca y Medrano

On February 14, 1998, at around 9:30 in the evening in Barangay Tambo, Lipa City, a violent incident occurred involving the beating and mauling of a man identified as Wilfredo Castillo (also referred to as Edoka).
The eyewitness, Marcial Morillo, while lying with his family at his house in Module Subdivision, heard a commotion marked by incessant dog barking.
Prompted by the disturbance, Morillo stepped outside and, from a distance of about 10 meters behind a PLDT telephone post, observed four individuals assaulting the victim.
He positively identified the group as consisting of Gerry Cuenca, Jackson Cuenca, Crisanto Agon, and Bernie Agon, noting that the accused were his long-time neighbors.

Marcial Morillo testified that he saw the accused acting in concert—a clear, detailed, and candid account.
According to his testimony:

The father and son pair (Crisanto Agon and Bernie Agon) were seen holding the victim’s hands (left and right respectively).
The brother pair (Gerry Cuenca and Jackson Cuenca) were identified as the ones beating the victim with a wooden instrument.
After the victim lost consciousness, the assailants cooperated in carrying his body toward the Calabarzon Highway, which leads in the direction of Batangas City.

Despite not witnessing the actual stabbing, the witness’s identification and description of the events remained vivid and consistent throughout cross-examination despite minor, non-material inconsistencies.

The following day, February 15, 1998, the victim’s body was discovered in a well situated in a forested area, approximately 15 meters deep and less than one-half kilometer from where the assault was reported.
An autopsy carried out by Dr. Corazon Sabile identified:

Multiple injuries on the head, including nine wounds (with two stab wounds affecting the right ear and frontal area).
A combination of contusions, lacerations, abrasions, and hematomas on various parts of the body.
Fractures on several ribs (2nd to 7th), an indication that the injuries were severe enough to cause death.
The cause of death was determined as hypovolemia secondary to multiple stab wounds, with circumstantial evidence also pointing to blunt trauma from the beating.

The recovery of the victim’s body in proximity to the alleged scene of the assault.
The presence of stab wounds and multiple abrasions that corroborated the physical altercation described by Morillo.
The fact that accused individuals were the last seen with the victim and later aided in his removal from the scene.

The prosecution emphasized that, although the witness did not see every detail (such as the moment of stabbing), the chain of circumstantial evidence linked the accused directly to the commission of the crime.
Appellants attempted to present alternative narrations, including an alibi stating that they were at the residence of Roger Dimaculangan during the incident; however, this defense was contested by the proximity of the locations and the speedy transfer possible by bicycle.

The case was initially filed with the RTC of Lipa City on March 17, 1998, charging the accused with murder under Article 248 of the Revised Penal Code, as amended by Republic Act 7659.
At trial, only the appellants (Gerry Cuenca and Crisanto Agon) were tried because some co-accused were at large, yet the accounts of the lone eyewitness and the circumstantial evidence were deemed sufficient for conviction.
The RTC sentenced the accused to reclusion perpetua and awarded a series of damages including indemnity for the victim’s heirs, actual damages, moral damages, and an award purported for loss of earning capacity (later modified by the higher court).

Appellants contended that the trial court erred in placing full reliance on the testimony of Marcial Morillo, a single eyewitness whose account, in their view, did not align entirely with common experience and was fraught with minor inconsistencies.

Appellants argued that the victim’s death should have been attributed solely to injuries from being beaten with a piece of wood, as witnessed by Morillo, rather than the multiple stab wounds noted in the autopsy report.

The accused maintained that they were not present at the scene of the crime, claiming an alibi that they were at Roger Dimaculangan’s residence at the time of the assault.
They argued that this alternative narrative was not properly considered by the trial court in its overall evaluation of the evidence.