G.R. No. 70836 - People vs. Tolentino y Mapua

On or about July 26, 1982, in Quezon City, Philippines, Alfredo Quitoriano y Bayot was fatally injured.
The initial information charged two persons with murder: Timoteo Tolentino y Mapua (alias "TEM") and an unidentified John Doe, suspected of acting in concert.

The information asserted that the accused, acting with evident premeditation and treachery, attacked the victim by throwing stones at his head and subsequently inflicting additional wounds with a stabbing instrument.
A reinvestigation conducted by the fiscal to determine the identity of the mysterious John Doe failed because the complainant could not present any witness to identify him, leading to the focus solely on Tolentino.
The core evidence of the prosecution was the testimony of eyewitness Bienvenido Ferrer, who alleged that he observed Tolentino throw a stone at the victim’s head from behind.
The prosecution also introduced a sworn statement from Ferrer, which detailed the sequence of events occurring at a carinderia where several persons, including members of the Tolentino family, were present.

Timoteo Tolentino entered a plea of not guilty and filed a demurrer to the evidence (a “Motion to Dismiss”), arguing that:

There was no evidence linking him to the stabbing of the victim.
The evidence suggested that the head injuries—particularly the fatal wound—were caused by a sharp instrument rather than by a stone.
Ferrer’s testimony was insufficient, as it did not corroborate that the stone actually hit the victim or caused the fatal injuries.

The defense moved for a judgment on the basis of the demurrer, thereby waiving the presentation of its own evidence.
An initial application for bail was denied on August 2, 1982; however, following the presentation of the prosecution’s evidence and the demurrer, a subsequent bail application was granted on July 18, 1983.

The trial court deferred ruling on the defense’s demurrer until all evidence was presented.
Eventually, the court rendered a judgment convicting Tolentino of murder, sentencing him to life imprisonment and ordering him to pay P15,000 as indemnity to the victim’s heirs.
Accused Tolentino subsequently appealed the conviction, raising multiple assignments of error centered on the insufficiency of the evidence linking him to the fatal injuries and the misinterpretation of the expert testimony.

The medico-legal witness, Dr. Gregorio Blanco, performed the autopsy on the victim and reported several injuries:

Among the head injuries recorded were an abrasion, a lacerated wound (fatal), and a contusion.
The fatal wound (Wound No. 2) on the victim’s head was described as a lacerated wound caused by a sharp instrument (e.g., a balisong), not by a stone.

While Ferrer testified that the stone thrown by Tolentino struck the back of the victim’s head, Dr. Blanco’s report contradicted this by attributing the fatal laceration to a sharp instrument.
The prosecution failed to adduce tangible evidence, such as the alleged stones used, and did not reconcile the discrepancy between the eyewitness account and the expert’s findings.

Whether the prosecution discharged its heavy burden of proving, beyond reasonable doubt, that Tolentino’s act of throwing stones was the proximate cause of the fatal injury.
Whether the circumstantial evidence, largely stemming from Ferrer’s testimony, was adequate to establish that Tolentino’s actions resulted in the victim’s death.

The issue of how to weigh the credibility of the sole eyewitness, Ferrer, against the expert testimony of Dr. Blanco who conducted the autopsy.
Whether the testimony of the medical expert should override the eyewitness account due to clear findings in the necropsy report.

Whether the evidence sufficiently demonstrated that Tolentino not only threw stones at the victim but did so in a manner that directly caused the fatal wound.
Whether there was any evidence establishing his participation in any conspiracy or his role as an accomplice in the fatal stabbing, given that the fatal injury did not correlate with the act of stoning.

Whether the standard of “beyond reasonable doubt” was met by the prosecution, considering the discrepancies in evidence and the presumption of innocence inherently enjoyed by the accused.