G.R. No. 91756 - People vs. Escoto y Gonzales

On April 10, 1985, at about 5:30 P.M., the Escoto brothers—Wilfredo (“Willie”) and Dominador (“Ogie”)—arrived at Mabina Cuales Vda. de Torno’s residence at 2237 M. Hizon Street, Sta. Cruz, Manila, initially seeking Alfred Torno.
After being denied entry by Mabina, the brothers left the premises, with Wilfredo vocally threatening, “Alfred, do not go out of that house alive. If I see you, I will kill you.”
As the Escoto brothers proceeded along M. Hizon Street, they encountered Robert Torno, who was walking alone.
In a brief chase, the brothers caught up with Robert. Mabina, who was about ten meters away, witnessed Wilfredo stab Robert in the left chest with a fan knife and then saw Dominador stab him as well.
Robert collapsed and subsequently died, with further evidence showing he sustained a total of twelve stab wounds, as confirmed by Dr. Marcial G. Cenido during the autopsy.

Mabina Torno testified in detail about her proximity to the crime scene and her clear identification of the assailants.
Joseph Calma, who was standing about fifty meters away, also testified that he saw Wilfredo clutching a fan knife and observed the sequence of events leading to Robert’s collapse.
Leticia Torno, the victim’s mother, provided testimony concerning funeral expenses incurred due to Robert’s untimely death.
Additional forensic evidence, such as the autopsy findings documenting twelve stab wounds, reinforced the eyewitness accounts.

An information was filed on July 16, 1985, against Raul Escoto and Dominador Escoto as conspirators in the murder of Robert Torno, although Wilfredo Escoto was not included in the information, likely due to his being at large.
Both accused entered pleas of not guilty when arraigned on September 18, 1985.
The trial court, after hearing all evidence and testimonies, convicted Dominador Escoto for murder, sentencing him to reclusion perpetua, while Raul Escoto was acquitted.

In all stages of the prosecution, both Raul and Dominador Escoto advanced the defense of denial cum alibi.
Raul Escoto testified that on the day of the incident, he was at his residence in Novaliches, Quezon City, working on a rush order for Ester Ramos, and initially claimed that Dominador was with his grandmother at Blumentritt.
Contradictory statements emerged from Raul’s testimony regarding the whereabouts of Dominador – ranging from being with his grandmother to being in the house in Novaliches and later assisting in the work.
Ester Ramos, upon testifying, confirmed she only saw Raul and his son “Jing-Jing” (and not Dominador), further exposing the inconsistencies in the defense’s alibi.
Dominador, when testifying, claimed he was at his grandmother’s residence until he left for Novaliches around six or seven P.M., a timeline that conflicted with other evidence.

The prosecution advanced qualifying or aggravating circumstances such as treachery, abuse of superior strength, and evident premeditation.
The evidence indicated that the confrontation was sparked by a prior mauling incident involving Wilfredo the night before, which might have motivated the attack against Alfred; however, Robert became the victim by mere chance.
The rapid succession of events, the spontaneous nature of the attack, and the physical circumstances—including the fact that only Wilfredo was armed—cast doubts on the applicability of treachery and abuse of superior strength as qualifying elements in the case.

Whether Mabina Torno’s clear and consistent eyewitness account, given her proximity to the crime scene, provided sufficient proof to identify Dominador Escoto as one of the perpetrators.
The extent to which other eyewitnesses and forensic evidence (e.g., the autopsy report) corroborated her account.

Whether the alibi presented by Raul and Dominador Escoto, which placed them away from the scene, was consistent and credible when weighed against the other evidence.
How the inconsistencies and contradictions in the defense’s narratives affected the overall reliability of their attempt to prove non-participation.

Whether the elements required to support findings of treachery, abuse of superior strength, and premeditation were present in the circumstances of the crime.
Whether the spontaneous and unpremeditated nature of the confrontation mitigated these aggravating factors under the law.