Case Summary (G.R. No. 36429)
The Case for the Prosecution
The prosecution presented the testimony of Manolito U. Manuyag, Jr., who detailed an altercation between members of the APO and TAU Gamma fraternities, culminating in the death of Fernando. On the night of the incident, Manuyag and a companion were confronted by a group of APO members, including CaAete, who attacked Fernando with wooden clubs and knives. Despite attempts to escape, Fernando was fatally assaulted. Witness Mario Sillar corroborated the situation, stating he observed a severe beating but acknowledged uncertainty regarding the weapons used.
Medical and Police Testimonies
Dr. Florante Bautista performed an autopsy and confirmed the cause of death was multiple stab wounds, some inflicted by what appeared to be bladed instruments. His report indicated specific fatal injuries, reinforcing the claim of a violent attack. Police were informed promptly, and testimonies established a timeline that implicated CaAete and his companions. Sillar's identification of CaAete, despite challenges regarding his description and inconsistency with physical evidence, played a critical role in the prosecution's narrative.
Defense and Alibi
CaAete’s defense revolved around an alibi, asserting he was at a police event during the time of the offense. He dismissed the accusations as stemming from personal animosity, narrating incidents between himself and Manuyag that might have influenced the latter's testimony against him. Likewise, Elmer Alipio, a co-accused, provided a similar disavowal of involvement and constructed his alibi based on his whereabouts during the critical timeframe.
Trial Court Findings
The Regional Trial Court observed the accounts of witnesses, ultimately finding Enrique CaAete guilty of murder under Article 248 of the Revised Penal Code, sentencing him to reclusion perpetua and ordering him to pay substantial damages to the victim's heirs. The court ruled out Alipio's culpability due to insufficient evidence linking him to the crime, primarily discrediting Manuyag's testimony while accepting Sillar's despite its contradictory nature.
Appellate Review
On appeal, CaAete challenged the trial court's conviction, asserting errors regarding the sufficiency of evidence, the reliability of witness Sillar, the applicability of treachery and superior strength as qualifying circumstances, and the overarching presumption of innocence. The appellate court meticulously scrutinized the testimonies and evidence, emphasizing the prosecution's
...continue readingCase Syllabus (G.R. No. 36429)
Case Overview
- The case involves an appeal by Enrique CaAete against the Decision of the Regional Trial Court of Quezon City, Branch 95.
- CaAete was convicted of murder and sentenced to reclusion perpetua.
- The incident occurred on February 21, 1994, resulting in the death of Fernando Obrino.
Facts of the Case
- Members of the ALPHA Phi Omega Fraternity (APO) and the Samahang Ilocano were friendly, while the TAU Gamma Phi Fraternity had conflicts with APO.
- A confrontation leading to a fatal incident occurred after a member of the APO threw a pillbox at a member of TAU Gamma.
- On the evening of January 20, 1994, John Eric del Nocho, a TAU Gamma member, was killed.
- On February 21, 1994, Manolito U. Manuyag, Jr. and Fernando Obrino were near a restaurant when they were approached and attacked by members of APO, including CaAete.
- The assailants were armed with knives and wooden clubs, leading to Fernando being mortally wounded.
- The attack was witnessed by Mario Sillar, who later provided testimony identifying CaAete as one of the assailants.
Testimonies
Prosecution Witnesses
- Manolito U. Manuyag, Jr. described the attack and the warning he received from Fernando upon seeing APO members.
- Mario Sillar witnessed the attack, identifying CaAete and stating he saw the victim being mauled.
- Dr. Florante Bautista performed an autopsy, detailing the multiple stab wounds on Fernando indicating the cause of death was due to stab wounds, with certain wounds being f