G.R. No. 130378 - People vs. Mataro y Elizaga

On or about October 23, 1992, in Quezon City, two accused—Arnel Mataro and Nick Perucho—were implicated in the killing of SPO1 Enrique Castillo, Jr. (also referred to as Enrique Castillo, Jr. y Balbin).
Two separate informations were filed: one against Mataro (Q-93-41704) and another against Perucho (Q-93-48440), both alleging a conspiracy to commit murder with treachery, superior strength, and evident premeditation.
The crime involved the use of firearms (an armalite and a .45 cal.) which were recovered after the accused allegedly returned to their vehicle.

Witness Victor Nilo Fernandez, a jeepney driver, testified that at around 4:00 P.M., he observed Castillo stop his vehicle and saw Mataro and Perucho disembark, converse with the victim, and later retrieve firearms from their car before shooting Castillo.
Witness Reden Guzman, riding in a jeepney about 9 to 10 meters away, corroborated witnessing the shooting at approximately 4:15 P.M.
NBI medico-legal officer Dr. Juan Zaldariaga provided expert testimony regarding the nature of the wounds, detailing three gunshot injuries consistent with an attack that occurred in phases with the victim in varying positions (standing, supine, and face down).
SPO3 Jaime Santos assisted in the identification process by accompanying Fernandez during two separate line-ups in which both accused were identified.

The accused invoked alibi and denial as part of their defense.
Defense witness Morieto Bello testified that he was with Mataro from 4:00 P.M. to 5:00 P.M. at a vulcanizing shop in Marikina when Mataro’s jeep was being fixed.
Another defense witness, Amy Pangilinan, claimed she was with Mataro in the afternoon of the incident, having gone to Antipolo to buy a pig, and that they experienced engine trouble, leading to a stop at a vulcanizing shop.
Appellant Mataro himself testified a similar account—leaving Fairview by noon, traveling to Antipolo, and stopping for repairs—while also noting his arrest on December 21, 1992, on unrelated suspicions.
Appellant Perucho presented testimony that he was in Aklan from June until November 1992, distancing himself from the events in Quezon City.

The Regional Trial Court, Branch 88 of Quezon City, found both accused guilty beyond reasonable doubt for murder.
The ruling imposed reclusion perpetua on each accused and directed them to indemnify the heirs of the victim with actual and moral damages and to pay the costs.
The initial award included actual damages computed partly on the victim’s loss of earning capacity and expenses, alongside a separate award for moral damages.

The accused argued that the trial court erred by convicting them despite the existence of reasonable doubt.
They contended that the identification of Mataro and Perucho was flawed, citing discrepancies such as the witnesses’ description of the vehicle (a Toyota Corona versus a gray Kia Pride mentioned in an unadmitted statement) and inconsistent age estimations (witnesses described Mataro as between 35 and 40 years old, contrary to his actual age of 24).
They invoked the “equipoise rule,” asserting that if the evidence was evenly balanced, the presumption of innocence should prevail.

The Office of the Solicitor General maintained that the eyewitness testimonies were positive, categorical, and unerring, with both accused being identified in separate line-ups.
Minor inconsistencies were argued to be characteristic of spontaneous, unrehearsed testimonies rather than deliberate error.
The prosecution argued that the conditions of visibility and the proximity of the witnesses afforded them a clear view of the events, reinforcing the credibility of their accounts.

The appellate court reviewed the computation of actual damages, particularly the loss of earning capacity, advocating that it should be based on the victim’s gross annual income minus necessary and incidental living expenses (estimated at 50%).
Adjustments were made: the award for loss of earning capacity was recalculated to approximately P724,966.00, temperate damages were set at P30,000.00, moral damages reduced to P50,000.00, and a death indemnity of P50,000.00 was imposed along with attorney’s fees of P24,000.00.
The total awarded sum to the victim’s heirs was modified to P903,966.00.

Whether the eyewitness identifications of the accused were credible and reliable enough to support a conviction beyond reasonable doubt.
Whether the trial court correctly applied the “equipoise rule” in the present case, considering the balance of evidence.
What is the proper method for computing actual damages, especially regarding loss of earning capacity based on the victim’s income and life expectancy.
Whether the discrepancies in vehicle description and age estimation materially affected the overall credibility of the eyewitness testimonies.
The appropriate quantum of moral damages and additional compensations considering both the nature of the crime and prevailing jurisprudence.