Title
People vs. Escoto y Gonzales
Case
G.R. No. 91756
Decision Date
May 11, 1995
Brothers Wilfredo and Dominador Escoto stabbed Robert Torno to death in Manila. Dominador's alibi failed; he was convicted of homicide, not murder, due to insufficient proof of treachery or superior strength.

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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