Case Summary (G.R. No. 118912)
Charges and Proceedings
Both accused were charged with murder under an information alleging that they, armed with a knife and a stone, attacked Manolito Hernandez, inflicting multiple wounds that resulted in his death. Upon pleading not guilty during their arraignment on December 9, 1982, a trial commenced with multiple testimonies provided by witnesses for the prosecution, indicating their involvement in the victim's death.
Prosecution's Evidence
Prosecution witnesses, including family members of the victim, testified that Manolito was involved in a drinking session and later got into an altercation with another individual named Juanito Cusi. After an unsuccessful attempt to pacify the situation, witnesses observed Quintin and Ricardo attacking Manolito after he had fled the initial conflict. Notably, a key eyewitness, Romeo Hernandez, the victim's younger brother, testified that he witnessed the assault from a distance and identified the assailants.
Defense's Position
The defense posited a different narrative, asserting that Quintin and Ricardo parted ways with Manolito before any attack occurred and thus could not have been responsible for the murder. They further questioned the credibility of the eyewitness account, claiming it was improbable and inconsistent.
Trial Court's Findings
The Regional Trial Court found the prosecution’s evidence sufficient for a conviction, highlighting the eyewitness's credibility and blatant confrontation of the victim at the time of the attack. The trial court ruled that the murder was qualified by treachery, as the assailants planned and executed the attack in a calculated manner. As a result, both were sentenced to reclusion temporal.
Appeal to Court of Appeals
The accused appealed their conviction to the Court of Appeals, which affirmed the lower court’s findings but modified the penalties. It ruled that the evidence did not support the aggravating factor of abuse of superior strength and granted a mitigating circumstance for Quintin, resulting in a lesser sentence compared to Ricardo.
Supreme Court's Review
Following a certification of the case to the Supreme Court, several critical issues arose regarding the appeal and its merits given that Ricardo had jumped bail. The Court exercised its discretion to proceed with the appeal despite this factor, citing the potential injustice that could arise if the appeal was dismissed.
Examination of Witness Credibility
The Supreme Court reviewed the credibility of the eyewitness testimony and found that the trial court’s assessments were sound. The defense’s claims regarding the unnaturalness of Romeo’s response during the attack were dismissed, emphasizing that a standard behavioral response cannot be expected in traumatic situations. Thus, the testi
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Case Overview
- The case involves appellants Quintin Castillo y Masangkay and Ricardo Castillo y Arce, charged with murder in connection with the death of Manolito Hernandez.
- The incident occurred on April 8, 1982, in Barangay Malakim Pook, Municipality of San Pascual, Batangas, Philippines.
- The information stated that the accused acted with intent to kill, using a knife and a stone, and inflicted sixteen wounds on the victim which led to his death.
Initial Proceedings
- On December 9, 1982, both accused, represented by counsel, pleaded not guilty to the charge of murder.
- A trial on the merits followed where multiple witnesses testified for the prosecution.
Prosecution Evidence
- Key witnesses included family members of the victim and law enforcement personnel.
- The victim, a seventeen-year-old, was last seen drinking with the accused and others before the altercation began.
- An altercation took place between the victim and another individual, Juanito Cusi, leading to the victim being pursued by his father, Buenaventura Hernandez.
- The witness, Romeo Hernandez, the victim’s younger brother, testified he saw the accused attacking his brother with a knife and a stone at approximately 10:45 p.m.
- Medical evidence presented by Dr. Johnny Ilustre confirmed the cause of death as severe cerebral hemorrhage due to multiple injuries inflicted by both sharp and blunt objects.
Defense Testimony
- The defense presented testimonies from the accused and others, asserting they were not present at the scene of the crime.
- The accused denied the prosecution's account and claimed they were misidentified and had not participated in the attack.
- They asserted Romeo could not have witnessed the crime as he was with their father at the