Case Summary (G.R. No. 143819)
Charge and Background
The formal charge against the appellants was established by the Information filed by Lipa City Assistant City Prosecutor Mario G. Mayuga, asserting that both accused had conspired and participated in the murder of Wilfredo Castillo, employing treachery and superior strength. The Regional Trial Court (RTC) of Lipa City ultimately found both guilty beyond reasonable doubt and sentenced them to reclusion perpetua.
Prosecution's Version of Events
According to the prosecution, at approximately 9:30 PM on February 14, 1998, Morcillo observed from a distance as Cuenca and Agon, along with two other unidentified assailants, attacked and beat Castillo using wooden implements. Morcillo recognized all three assailants due to their familiarity as neighbors. After Castillo lost consciousness, Morcillo claimed the attackers carried his body toward a nearby highway. The following day, Castillo's body was discovered in a well, showing signs of severe physical injuries resulting from multiple stab wounds.
Defense's Version of Events
The defense brought forth an alibi, asserting that Cuenca and Agon were located at a different residence during the time of the crime. They claimed that other individuals were present and could corroborate their alibi. The defense contended that the lack of eyewitness testimony regarding how Castillo was stabbed undermined the prosecution's case.
Trial Court's Ruling
The RTC found Morcillo's testimony credible and detailed, concluding that it provided a vivid account of the events, thus supporting a finding of guilt based on conspiracy and treachery. The trial court rejected the appellants' defenses of denial and alibi. It determined that both accused actively participated in the killing, which was facilitated by their conspiracy.
Issues Raised by the Appellants
The appellants raised three main issues on appeal: (1) the weight given to Morcillo's testimony, (2) the trial court’s interpretation of the cause of death, suggesting that injuries caused by wood rather than stab wounds led to Castillo's death, and (3) the trial court's dismissal of their alibi.
Court's Assessment of Witness Credibility
The appellate court upheld the trial court’s assessment of the credibility of Morcillo’s eyewitness testimony, stating that the testimony was not undermined by minor inconsistencies. It reaffirmed the principle that a single credible witness could form a sufficient basis for conviction, emphasizing the quality over quantity of evidence.
Establishment of Cause of Death
Contrary to the appellants' argument, the appellate court maintained that circumstantial evidence, including Morcillo's eyewitness account and the autopsy findings indicating multiple stab wounds, pointed convincingly to their culpability. The finding of numerous stab wounds was decisive in establishing the manner of Castillo’s death, notwithstanding the defense’s claims.
Alibi and its Insufficiency
The appellate court noted that the defense of alibi is often considered weak and difficult to substantiate. The distance between the alleged location of the accused at the time of the murder and the crime scene was not sufficiently far to support the impossibility of presence. Thus, the court concluded that the appellants failed to convincingly establish their alibi.
Findings on Conspiracy and Treachery
The court affirmed the RTC's finding that treachery characterized the murder,
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Case Background
- This case concerns the appeal of Gerry Cuenca and Crisanto Agon against their conviction for murder by the Regional Trial Court (RTC) of Lipa City.
- The RTC's decision was rendered on February 7, 2000, finding the accused guilty beyond reasonable doubt under Article 248 of the Revised Penal Code, as amended by Republic Act 7659.
- The appellants were sentenced to suffer the penalty of reclusion perpetua and were ordered to pay various amounts in damages to the heirs of the victim, Wilfredo Castillo.
Incident Overview
- The incident occurred on February 14, 1998, at approximately 9:30 PM in Barangay Tambo, Lipa City.
- The accused allegedly attacked Wilfredo Castillo using bladed and pointed instruments while conspired together with intent to kill.
- A single eyewitness, Marcial Morillo, testified about the event, identifying the four assailants: Gerry Cuenca, Jackson Cuenca, Crisanto Agon, and Bernie Agon.
Testimony of the Prosecution
- Marcial Morillo witnessed the assault from a distance of about ten meters, recognizing all four assailants.
- Morillo described the scene where Crisanto and Bernie Agon held Castillo’s hands while Gerry and Jackson Cuenca beat him with pieces of wood.
- The mauling lasted approximately twenty minutes, leading to Castillo losing consciousness.
- The following day, Castillo's body was discovered in a well, showing numerous stab wounds and injuries indicative of a violent death.
Autopsy Findings
- An autopsy conducted on February 15, 1998, revealed:
- Multiple stab wounds, contusions, and abrasions on Castillo's body.
- Significant injuries to the head and torso, wit