Title
People vs. Castelo y De Castro
Case
G.R. No. L-48070
Decision Date
Dec 26, 1984
Medardo Castelo was acquitted of murder after the Supreme Court found insufficient evidence, citing unreliable witness testimony, inadmissible hearsay, and a credible alibi, upholding the presumption of innocence.
murder charges
bias against the accused
strong evidence

Case Summary (G.R. No. L-48070)

Criminal Information and Conviction in the Trial Court

The Information alleged that, acting in conspiracy and common accord with Romulo (who remained at large), the accused and Romulo, both armed with firearms, attacked Villanueva with intent to kill, qualifying the offense by either treachery or evident premeditation. It further alleged that they fired and inflicted gunshot and lacerated wounds resulting in hemorrhage and shock that directly caused death.

On arraignment on March 31, 1975, the accused, assisted by counsel de officio, pleaded not guilty. After trial, the Court of First Instance found the accused guilty beyond reasonable doubt of murder, with the qualifying circumstance of treachery, which included nocturnity, and sentenced him to reclusion perpetua. The court ordered indemnification of the heirs of the deceased in P12,000.00 and imposed the accessory penalties prescribed by law.

Prosecution’s Theory and Evidence

The prosecution’s version, as summarized in the Solicitor General’s Manifestation, relied on alleged eyewitness testimony of the barrio captain Remo Madlangbayan. Remo claimed that on the night of September 23, 1969, while returning home after a prolonged conversation with others at Bautro’s store, he remembered he had something to tell Villanueva, his overseer and helper in the family coconut plantation. Remo said he proceeded to the rear part of Bautro’s house near the area where Villanueva tethered his horse. Remo then claimed he heard successive gunshots, ducked and lay flat, and watched through a gap in a row of “San Francisco” plants as Villanueva staggered and fell. Remo further alleged that the accused emerged from behind the stable and Romulo from behind a coconut tree, and that the brothers approached the body. Remo asserted that the accused fired at Villanueva’s head, took Villanueva’s pistol, and uttered the words: “Patawarin mo ako Carding at ako’y naganti lamang,” after which both brothers fled. Remo claimed he reported the killing by writing a letter to the Chief of Police of San Juan and requested an investigation.

The prosecution also presented sworn statements executed before the police a day after the killing. Dominador Sornito, whose sworn statement was marked Exh. D, implicated the accused and Romulo and declared that he heard successive shots, saw the accused and Romulo emerging from the direction of the gunshots, concluded the Castelo brothers killed Villanueva, and that the accused carried a carbine. Numeriano Sandro, whose sworn statement was marked Exh. C, recounted that shortly before the incident he was told by the brothers that Villanueva was present at a store and would be shot, and that when shots were heard it would mean Villanueva was killed; Sandro also claimed he later met the accused and Romulo running and was told that “Carding” was already finished.

Medical evidence came from a medical examination by Dr. Victoriano V. Salud on September 24, 1969. The medical certificate described multiple gunshot wounds and lacerated wounds, and it concluded that the cause of death was gunshot wounds resulting in hemorrhage and shock, with the lacerated wounds also fatal.

Accused’s Denial and Alibi

The accused denied participation in the ambush and killing and raised an alibi. He testified that on the night of September 23, 1969, he was at the clinic of Dr. Ona, where he kept watch over his sick brother Vicente from seven o’clock in the evening to twelve midnight, without leaving the premises. The alibi was corroborated by Vicente Castelo.

To undermine Remo’s claim of eyewitness presence, the defense presented Rogelio de Torres, who had been among the group that went to Bautro’s store immediately prior to the killing. De Torres testified that immediately after the shots, Remo and Precing arrived at his in-law’s house, asked what happened, and sent someone to inquire. They then went to the place where Villanueva lay dead and Remo asked who had done it.

The defense also sought to neutralize Sandro’s sworn statement by presenting Sandro as a witness. Sandro testified that Remo had him fetched by policemen the day after the killing, that he was maltreated—hit and kicked by Sgt. Valdez—and instructed to implicate the accused and Romulo as the killers. Sandro denied seeing the Castelo brothers before or after the killing, denied that they told him of their plan, and denied that they announced Villanueva’s death to him.

The Primary Issue: Credibility of the Prosecution’s Alleged Eyewitness

The Court treated as “primordial” the question whether the trial court erred in giving credence to the lone testimony of Remo Madlangbayan as an eyewitness identifying the assailants. The trial court’s conviction was described as resting substantially on the weakness of the alibi. The appellate review centered on whether guilt could be established on the strength of the prosecution’s evidence rather than on the weakness of the defense.

Appellate Court’s Evaluation of Evidence and Constitutional Error

The Court held that the trial court failed to observe the fundamental rule that conviction must be sustained by the strength of the prosecution’s own evidence. It found positive evidence indicating that during the initial police investigation, Sandro and Sornito were the only witnesses to the killing. The record showed that the Chief of Police, Vicente Peradilla, testified that policemen returned with the eyewitnesses and identified them as Dominador Sornito and Numeriano Sandro. Corporal Rufino Tejada corroborated that Remo directed investigators to speak to Sornito and Sandro because they knew something about the case.

The Court further ruled that Sornito’s sworn statement could not be treated as valid evidence at trial because Sornito died before trial and was never presented in court. The Court considered the sworn statement therefore hearsay and stated that the trial court’s admission of it was erroneous. It added that the trial court’s reliance on this hearsay statement violated the accused’s constitutional right to confrontation under Sec. 19, Art. IV, 1973 Constitution. The Court cited People vs. Lavarias to emphasize that reliance on affidavits without the accused’s opportunity to test the witness’s credibility through cross-examination is impermissible under the confrontation clause.

As to Numeriano Sandro, the Court observed that he retracted his prior written sworn statement in court, and it treated that recantation as effectively obliterating the evidentiary value of the earlier statement. The Court reasoned that Sandro came to testify for the accused and that Sandro explained he had been forced to implicate the accused by being maltreated by Sgt. Valdez. The prosecution, the Court noted, failed to rebut the claim of coercion.

The Court also found significance in the prosecution’s belated reliance on Remo. It stated that the murder information appeared filed purely on the basis of the sworn statements of Sornito and Sandro and that, in its view, Remo’s testimony did not fit a credible timeline. It noted that Remo allegedly delayed giving an account of the incident to the fiscal for about five years after the killing, despite allegedly being in a position to give information promptly. The Court rejected the explanation that Remo was busy attending to the body and waiting for parents and an autopsy, holding that a delay of about five years and three months defied the “grain of human experience.”

The Alleged Letter and Inconsistencies in Remo’s Account

The Court addressed Remo’s asserted “letter” to the Chief of Police as a report immediately after the incident. It found that the prosecution never presented the letter itself and that the claim that it was lost was admitted in testimony. It also found Peradilla’s testimony undermined the letter’s existence or, at minimum, showed that Peradilla did not read or even see it. The Court observed that the police testimony indicated the letter contained a request for investigation and a report that Villanueva was ambushed, but not the identity of the culprits.

The Court concluded that the trial court’s reliance on Remo’s eyewitness account was undermined by the internal improbabilities and by lack of corroboration. It noted that Remo testified he was about fifteen meters away from Villanueva when the shots were fired and killed. It further noted that Remo claimed to have heard exact words spoken by the accused after the headshot. The Court deemed it incredible, given the alleged distance and the claimed proximity and noise of Villanueva’s horse, which it found would have naturally reacted in panic during gunfire.

The Court also highlighted inconsistencies between Remo’s testimony and earlier police accounts. Remo claimed he pinpointed the brothers in the letter and that the police therefore knew the details he provided. Yet other prosecution witnesses described only a request for investigation and did not mention that the letter contained identification of the killers. The

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