Case Summary (G.R. No. 91756)
Summary of Events
On April 10, 1985, Dominador Escoto and his brother Wilfredo sought to confront Alfred Torno, the brother of Robert Torno, at the residence of Mabina Cuales Vda. de Torno. After being denied entry, Wilfredo threatened Alfred, stating he would kill him if he left the house. Shortly thereafter, the Escoto brothers encountered Robert Torno and, after a brief pursuit, attacked him with a fan knife, resulting in his death from multiple stab wounds.
Witness Testimonies
Mabina Torno witnessed the attack and identified both Escoto brothers as the perpetrators. She described Wilfredo stabbing Robert, while Dominador held him. Another witness, Joseph Calma, corroborated this by observing the encounter from a distance. An autopsy confirmed Robert's death was due to twelve stab wounds.
Indictments and Arraignment
On July 16, 1985, charges were filed against the Escoto brothers. However, Wilfredo was not included in the indictment, likely due to his absence at that time. Both Dominador and Raul Escoto pleaded not guilty at their arraignment on September 18, 1985. Dominador was later found guilty of murder and sentenced to reclusion perpetua, while Raul was acquitted.
Defense Claims
Both accused utilized the defense of alibi. Raul claimed he was busy working at his residence in Novaliches throughout the day of the incident and asserted that he was unaware of the situation until two weeks later. He presented Ester Ramos as a witness to support his alibi. Dominador, on his part, stated he was visiting his grandmother at a nearby location during the time of the attack.
Court's Findings on Witness Credibility
The court found both eyewitness accounts compelling, particularly those of Mabina Torno, as they were consistent and clear. The court emphasized that positive identification of the assailants outweighs the simple denial from the accused. The testimonies provided no indications of ill motives from the witnesses, thus supporting their credibility.
Analysis of Alibi Defense
However, the claim of alibi was effectively dismantled. Evidence presented by the defense contradicted itself and also failed to account for the proximity of Dominador’s alleged location to the crime scene. His assertions of being at his grandmother's house were deemed insufficient to establish that he could not have been present at the location of the attack at the time it occurred.
Consideration of the Aggravating Circumstances
The prosecution alleged the presence of treachery and abuse of superior stre
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Case Overview
- The accused-appellant, Dominador Escoto y Cruz, seeks to overturn his conviction for murder in Criminal Case No. 85-37810 by the Regional Trial Court of Manila, Branch 13, which was decided on September 11, 1989.
- Dominador was sentenced to reclusion perpetua for his role in the murder of Robert Torno, with the prosecution presenting multiple eyewitnesses and forensic evidence against him.
Incident Description
- On April 10, 1985, around 5:30 PM, the Escoto brothers, Wilfredo and Dominador, approached Mabina Cuales Vda. de Torno at her residence, seeking to confront Alfred Torno, the elder brother of the victim.
- Mabina denied them entry, prompting Wilfredo to threaten Alfred, declaring he would kill him if he left the house.
- Shortly after this confrontation, the Escoto brothers encountered Robert Torno, who was walking nearby. Without warning, they pursued him and attacked him with a fan knife.
Eyewitness Testimonies
- Mabina Cuales Vda. de Torno: Witnessed Wilfredo stab Robert in the chest, followed by Dominador's attack. She was about ten meters away and confirmed that Dominador held Robert during the stabbing.
- Joseph Calma: Observed the attack from a distance of approximately fifty meters and saw Wilfredo wielding a fan knife. He also noted Raul Escoto's presence nearby.
- Dr. Marcial G. Cenido: Conducted an autopsy revealing that Robert died from twelve stab wounds.
Prosecution's Case
- The prosecution filed an information against both Raul and Dominador Escoto for mu