G.R. No. 124916 - People vs. Almanzor y Roxas

Ricky Quimzon, along with three co-accused (Salvacion Lacsarom, Canoto Cabero, and Edgardo Detona), was charged with the murder of Marlo Casiong.
The events occurred on or about March 7, 1992, in the Municipality of Burauen, Leyte, during a benefit dance at a social hall.
According to the Information, the accused, in concert and with treachery and abuse of superior strength, attacked and fatally wounded Marlo Casiong with short bolos (locally known as apisao/pisao).

During the dance, an accidental bump between Marlo Casiong and Quimzon occurred, which set off a chain of events.
Salvacion Lacsarom invited Marlo to step outside the hall for a private conversation, prompting Emolyn Casiong (Marlo’s sister) and Rommel RedoAa to follow.
Outside, Emolyn observed that Quimzon along with Canoto and Edgardo hurried out and overtook them.
According to Emolyn’s testimony:

Salvacion pushed Marlo towards the group of accused.
Canoto grabbed Marlo’s wrist and repeatedly stabbed him with a bolo.
Edgardo then delivered two stab wounds at the back.
As Marlo attempted to escape towards a nearby health center, Quimzon held onto his hands, causing him to fall, and then proceeded to stab him repeatedly on his back.

Despite efforts to transport Marlo to the hospital by Emolyn and other persons, he died before reaching medical help.

Quimzon claimed an alibi, asserting that he was in Barangay Patag attending another benefit dance during the incident.
He maintained he did not know the other accused and denied stabbing Marlo Casiong.
His alibi was corroborated by two defense witnesses, including the Barangay Chairman and a Barangay Councilor.
Quimzon was included as an accused purportedly because he refused to testify in favor of the prosecution.

The Regional Trial Court of Tacloban City (Branch 16) found Quimzon guilty of murder under Article 248 of the Revised Penal Code, imposing the penalty of reclusion perpetua.
The court noted two qualifying circumstances in the offense: treachery and abuse of superior strength (with the latter absorbed by the former).
On the civil aspect, the court ordered the payment of:

P53,000.00 as actual expenses for the victim’s wake and burial (though only a smaller evidenced amount was proven).
P75,000.00 as moral damages to the victim’s mother.

The decision was later modified, with the imposition of an indeterminate sentence (prision mayor to reclusion temporal) and adjustments in civil damages awards.

The trial court allegedly erred in establishing the crime’s corpus delicti by relying on Dr. Adelaida Asperin’s testimony regarding the autopsy report.
Quimzon argued that since Dr. Asperin did not personally examine the body (Dr. Amparo Villanueva did), her testimony should have been inadmissible hearsay.

The second error focused on the credibility of the lone prosecution witness, Emolyn Casiong:

Quimzon challenged the reliability of her testimony, citing her delay in submitting an affidavit and her delayed appearance as a witness.
He asserted these factors weakened the weight of her identification of him as one of the perpetrators.

Whether the trial court erred in proving the corpus delicti of murder by relying on the testimony of an allegedly incompetent witness (Dr. Asperin) regarding the autopsy report.
Whether the trial court improperly gave undue credence to the testimony of Emolyn Casiong, the sole prosecution eyewitness, thereby affecting the conviction of the accused.
Whether the alibi defense and other mitigating circumstances (including the alleged minority of the accused at the time of the crime) were improperly considered or dismissed by the trial court in sentencing and imposing the penalty.