G.R. No. 102366 - People vs. Vasquez

The case involves the accused-appellants, Hector Vasquez and Renato Vasquez, who were charged with the murder of Primo Dollete.
The prosecution alleged that the brothers knowingly assaulted Dollete by boxing him and hitting him with a wooden cane, after which they dragged him to the river bank and submersed him, leading to his death.
The incident is said to have occurred on July 14, 1968, in the Municipality of Panit-an, Capiz.
The defense, however, maintained that the accused were not present at the scene but were in Iloilo City at the time, and that the victim’s death was the result of an accidental drowning when the banca (small boat) he rode on capsized.

Although the alleged killing occurred in 1968, the formal charges were not filed until August 1986, nearly 18 years later.
The delay was attributed to administrative irregularities in the handling of the case: missing records such as the warrants of arrest and bail bonds, court transmission issues, and delay in orders by successive judges.
The case was initially investigated by the Capiz Philippine Constabulary and later transferred through various judicial levels before finally reaching the Regional Trial Court (RTC), Branch 17, of Roxas City.

Upon arraignment in 1986, both accused pleaded not guilty and later posted new bail bonds as required by court order.
During trial, the prosecution presented eyewitness testimonies and circumstantial evidence to prove that Dollete was attacked, beaten, and then drowned by the Vasquez brothers.
Key prosecution witnesses (Loreno Ocante, Jose Daliva, and Jesus Diosana) testified to having seen the accused deliver multiple blows to Dollete and subsequently drag him to the river.
The trial court, after weighing the mass of evidence, convicted the accused beyond moral certainty of murder, sentencing them to reclusion perpetua, among other penalties.

Testimonies of eyewitnesses described a violent encounter in which Hector was seen boxing Dollete while Renato allegedly struck him with a wooden cane. Specific details, such as the length and diameter of the wooden cane, were provided.
The defense introduced evidence in support of an alibi and presented the theory that the victim’s death was purely accidental, emphasizing that the accused were with a third party at Aurelio Datiles’ residence in Iloilo City at the time.
The autopsy report, conducted by Dr. Edilberto Bellosillo, revealed that the victim’s death was due to asphyxia secondary to drowning and did not show the expected external injuries on the face, neck, or abdomen that the prosecution’s narrative would require.
Additional forensic findings, including the presence of an old subcutaneous hematoma on the occipital portion of the head and the absence of marks on other critical areas, further weakened the prosecution’s version of events.

The prosecution witnesses offered a narrative of premeditated violence leading to homicide; however, their testimonies contained inconsistencies regarding the sequence of events and the nature of the injuries.
The defense argued that these discrepancies, along with the lack of corroborative physical evidence of a violent assault, cast serious doubts on the veracity of the prosecution accounts.
Accusations arose that some witnesses might have been motivated by personal animus or other ulterior motives, further diminishing their credibility.

Evidence was presented showing that Hector Vasquez was only 17 years old at the time of the incident, a fact that has implications on the imposition of the penalty of reclusion perpetua.
The issue of criminal liability in relation to the age of the accused became one of the points argued in the appeal.

Whether the evidence presented by the prosecution was sufficient to establish the guilt of the accused beyond reasonable doubt.

The reliability and consistency of the eyewitness testimonies, given the discrepancies and the possibility of rehearsed statements with ulterior motives.
The contradiction between the physical (forensic) evidence, which indicated drowning without significant blunt trauma, and the narrative of a violent beating followed by drowning.
Whether the defense’s alibi and the alternative theory of accidental drowning were properly considered and adequately supported by the evidence.
The propriety of sentencing Hector Vasquez to reclusion perpetua in connection with the fact that he was a minor (17 years old) at the time of the alleged offense.
The impact of the long delay in filing the charges on the reliability of the evidence and witness testimonies.