Case Digest (G.R. No. 151834)
Facts:
People of the Philippines v. Juan G. Escote, G.R. No. 151834, June 08, 2004, First Division, Davide Jr., C.J., writing for the Court.On 31 January 2000, an information for murder was filed charging Juan G. Escote, Roland Garcia, Angelito Lisona, Joey Vic Peras, and one alias Buboy with the killing of Carlos Duenas alleged to have occurred on 16 June 1999 in Meycauayan, Bulacan. The information alleged that the accused, armed with firearms and with intent to kill, attacked and shot Duenas with evident premeditation, abuse of superior strength, and treachery. Upon arraignment the named accused pleaded not guilty; the true identity of one accused remained unknown.
The prosecution presented eyewitnesses who placed a gray Lancer box-type car at the scene that evening and positively identified Escote as the driver of that car and as the person who alighted and shot the driver of an orange Honda Civic (the victim). Liza de la Cruz testified that she saw and was glared at by the man in the driver’s seat before hearing gunshots; Ricardo Caitum testified he saw a man alight from the gray Lancer and shoot the driver; Allan Manalo noted the car’s plate number. The victim died of hypovolemic shock from a gunshot wound to the left lower extremity. Escote was identified in open court by both Liza de la Cruz and Ricardo Caitum.
Escote testified as defense witness, claiming alibi and denial: he asserted he was already in hiding in Camiguin Island at the time of the offense, having escaped custody earlier and later arrested in Quezon City; he also alleged he was framed through information supplied by a person named Willy allegedly tortured by authorities. He denied knowing the other accused.
The Regional Trial Court, Malolos, Bulacan, Branch 78 (Judge Gregorio S. Sampaga) rendered a decision dated 15 October 2001 finding Escote guilty beyond reasonable doubt of murder, giving credence to the positive identifications, rejecting Escote’s uncorroborated alibi and denial, and convicting him with treachery as the qualifying circumstance; the court acquitted the other named accused for lack of proof. The trial court imposed reclusion perpetua and awarded P50,000 as death indemnity and another P50,000 as indemnity ex delicto to the heirs.
Escote appealed to the Supreme Court. The Office of the Solicitor G...(Subscriber-Only)
Issues:
- Whether the conviction should be overturned on the ground of reasonable doubt due to alleged poor visibility, inconsistent witness statements, and an alibi/frame-up defense.
- Whether treachery was properly appreciated as a qualifying circumstance.
- Whether the trial court’s civil awards (duplicative...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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