Case Digest (G.R. No. 137610-11)
Facts:
People of the Philippines v. Manuel Gutierrez (At Large), Juancho Gutierrez (At Large), Esting Carino (At Large) and Zacarias Castillo, G.R. Nos. 137610-11, February 06, 2002, First Division, Puno, J., writing for the Court.On March 23, 1992 an information was filed charging Manuel Gutierrez, Juancho Gutierrez, Esting Carino and Zacarias Castillo with multiple murder and multiple frustrated murder for a predawn ambush on January 8, 1992 in Barangay Sanlibo, Bayambang, Pangasinan. The four were alleged to have fired at close range upon a Sarao passenger jeep, killing Vicente de Leon, Aldrin (Aldrin/Aldren) de Leon and Guillermo Tapiador, Jr., and wounding several others. The information invoked treachery and premeditation under the Revised Penal Code (Arts. 248 and 6 as recited in the information).
Only Zacarias Castillo was tried; the other accused remained at large. Prosecution witnesses—principally Lorenzo de Leon and Catalina de Leon—testified that four men (the accused) blocked and sprayed the jeep with bullets at about 5:00 a.m.; the headlights allegedly illuminated the assailants and the firing lasted some minutes. Police recovered empty shells at the scene (M-16, carbine/.30 cal., Garand), and doctors performed post‑mortems on the three dead and treated the wounded; medical testimony described penetrating gunshot wounds causing cardiorespiratory arrest in the fatalities and serious wounds to several survivors (one of which, Catalina, the physician said would likely have been fatal without prompt treatment).
At trial Castillo denied participation and offered an alibi: employment records and testimony of co‑workers and a live‑in partner placing him in Antipolo working from January 7–9, 1992. The purported wage voucher was not identified by the custodian in court. The defense also elicited testimony that Castillo had not visited his hometown during the relevant period.
The trial court found Castillo guilty of three counts of murder and four counts of frustrated murder, acquitted him of illegal possession of firearm, and imposed reclusion perpetua and other pen...(Subscriber-Only)
Issues:
- Did the trial court err in accrediting the testimonies of the prosecution witnesses (Lorenzo and Catalina de Leon)?
- Did the trial court err in rejecting the accused-appellant Zacarias Castillo’s defense of alibi?
- Did the evidence support the trial court’s characterization and number of convictions (three counts of murder and four c...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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