G.R. No. 74156 - Globe Mackay Cable vs. National Labor Relations Commission

The case involves the People of the Philippines charging Joseph San Jose y Gregorio and Jonathan San Jose y Gregorio (the San Jose brothers) with murder under Article 248 of the Revised Penal Code.
The charges arose from an incident on or about June 2, 2002, at Rodriguez, Province of Rizal, Philippines, where the accused allegedly, in conspiracy and armed with kitchen knives, attacked and fatally stabbed Carlito Espino y Oreo.
Jonathan San Jose, a minor at the time (17 years old), and his older brother Joseph were implicated in an assault described as willful, unlawful, and felonious, with attendant qualifying circumstances relating to the use of superior strength and treachery (later modified to abuse of superior strength by appellate courts).

Jilito testified that during a baptismal celebration held on a vacant lot beside the victim’s residence, he observed the San Jose brothers entering the scene amid a commotion involving Carlito Espino and his friends.
According to his initial account, Joseph stabbed Carlito from the front while Jonathan, by embracing him from behind, stabbed him on the side.
Jilito’s testimony also mentioned that this was not the first altercation between the brothers and the victim, recalling an earlier incident on New Year’s Day where a lead pipe was allegedly used on Carlito.
However, his narrative contained inconsistencies regarding the exact location of the stabbing (in front of the house versus at a nearby store) and the sequence of events, including the victim’s ability to run away before being caught and stabbed again.

The autopsy report, prepared by Dr. Pierre Paul Carpio, noted that the victim sustained a single fatal stab wound at the abdomen (right hypochondriac) which lacerated vital structures including the pericardial sac, right ventricle, and right lung.
This finding conflicted with Jilito’s repeated testimony that there were two separate stab wounds inflicted by the two accused.

Jocelyn Espino, identified as the victim’s sister, testified that at the time of the commotion the victim was outside while other family members, including Jilito, were inside the house. Her testimony indirectly contradicted the assertion that Jilito witnessed the actual stabbing.
The defense presented testimonies from the accused themselves, with Joseph claiming that he was at home eating when a commotion was reported, and Jonathan asserting that he was about to leave for work when barangay tanods arrived to arrest him.
The time elapsed between the crime (2002) and the arrests (2005) – approximately three years – was also highlighted as an unusual delay in apprehending the accused.

In 2003, both accused were considered at large despite the issuance of arrest warrants, with their case eventually archived until their arrests in 2005.
Both were arraigned on separate dates in 2005 and pleaded not guilty.
The trial court, Branch 76, Regional Trial Court of San Mateo, Rizal, rendered a decision on May 12, 2010, finding the accused guilty of murder.
The trial court sentenced Joseph San Jose y Gregorio to suffer reclusion perpetua and Jonathan San Jose y Gregorio to an indeterminate penalty subject to mitigating circumstances as a minor, in addition to awarding death and moral damages to the victim’s heirs.

Both accused appealed the trial court decision.
The Court of Appeals, in its decision dated August 31, 2012, affirmed the trial court’s ruling with some modifications: it adjusted Jonathan’s penalty and added exemplary and temperate damages with accrued interest for the victim’s heirs.
The appellate court relied heavily on the testimony of Jilito, regarding his positive identification of the accused as the perpetrators, despite noted inconsistencies.

The exact location of the stabbing (whether in front of the house, a vacant lot, or near a store).
The number of stab wounds inflicted (one fatal wound per the autopsy versus two as testified by Jilito).
Variations in the sequence of events, including the victim’s movements during the attack.

The delayed arrest of the accused (three years post-crime), which raised questions about the preservation and reliability of evidence.
The conflicting testimonies between family members, especially Jocelyn’s indication that Jilito did not witness the incident firsthand.

The defense argued that the single fatal stab wound indicated an absence of the qualifying circumstance of abuse of superior strength, thereby undermining the prosecution’s narrative of a concerted and elaborate attack.

Whether the prosecution successfully discharged its burden to prove beyond reasonable doubt that the San Jose brothers committed the crime of murder against Carlito Espino.

Consideration was given to the evidentiary inconsistencies in the eyewitness testimony, particularly the conflicting accounts regarding the number and location of stab wounds.
The issue also involved whether the delay in arrest and the potential unreliability of key witnesses (including the discrepancies in Jilito’s account) established reasonable doubt regarding the accused’s guilt.

Whether the material inconsistencies and unusual circumstances in the evidence, including conflicting forensic findings and testimonies, warranted an acquittal in light of the constitutional presumption of innocence.