Case Summary (G.R. No. 85043)
Charges and Initial Proceedings
Glenn Hatton was charged with murder, characterized by treachery and evident premeditation, as outlined in the initial complaint. Upon arraignment, Hatton pleaded not guilty. The prosecution's case relied on the testimony of eyewitnesses who provided details of the event leading to Algarme's death.
Testimonies of the Prosecution
Eyewitnesses Edgardo Ongue and Romeo Basierto testified that Algarme was attacked during a fiesta celebration. Ongue saw a tall man stab Algarme while Basierto, who chased the assailant, recognized Hatton as the attacker. The victim succumbed to a stab wound that caused massive hemorrhage after being rushed to the hospital. The witnesses corroborated their observations about the attack and the assailant's height and features.
Defense and Alibi
Hatton's defense was primarily alibi; he claimed that he spent the evening at a friend’s house during the time of the crime. His alibi was supported by testimonies from individuals present during the gathering. Hatton also contested claims asserting he was the attacker by stating he is left-handed, challenging the assertion that the fatal blow had been made with a right hand.
Trial Court's Judgment
The trial court found Hatton guilty of murder, imposing the penalty of reclusion perpetua and ordering him to pay damages to Algarme’s heirs. The decision asserted that the evidence produced by the prosecution was compelling.
Appellant's Arguments
Hatton raised multiple issues in his appeal against the trial court’s judgment, including claims of bias from the judge, the relevance of being left-handed, the validity of eyewitness identifications, and the alleged failure of the court to give weight to his defense.
Judge's Conduct During Trial
Hatton argued that the trial judge displayed bias and conducted the examination of witnesses in a leading manner, favoring the prosecution. The appellate court examined the trial transcripts, ultimately concluding that while the judge was active in questioning, it did not create bias against the defense.
Eyewitness Identification Credibility
The appellate court scrutinized the reliability of the eyewitness identification of Hatton. It highlighted the issue of identification taking place not in a proper lineup, but rather in a suggestive manner where police indicated him as their suspect, which is a substantial concern in legal proceedings regarding due process rights.
Left-Handedness as a Factor
The appeal pointed out the trial court's dismissal of Hatton’s handedness as a trivial detail. However, the appellate court disagreed, emphasizing that the nature of the stab wound delivery was significant and could pertain to the identity of the assailant, given Hatton’s claim as a left-handed individual.
Pre-Trial Identification Concerns
Witness Ongue’s identification of Hatton was deeply scrutinized, considering he was shown Hatton as the suspect without a proper process of identification in place. The co
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Case Overview
- The case concerns Glenn Hatton, the accused-appellant, who was charged with murder for the death of Faustino Algarme on August 29, 1986.
- The charge was based on a complaint alleging that Hatton attacked Algarme with a knife, intending to kill him through treachery and evident premeditation.
- The trial court eventually found Hatton guilty of murder, resulting in a sentence of reclusion perpetua and financial indemnities to the victim's heirs.
Factual Background
- The incident took place during the town fiesta in Catarman, Northern Samar, where Algarme and his companions had been drinking.
- Witnesses Edgardo Ongue and Romeo Basierto testified that Algarme was approached and stabbed by a tall man, later identified as Hatton.
- Ongue witnessed the attack and attempted to assist Algarme, who called for help.
- Basierto chased the assailant, recognizing Hatton when he turned his face towards him.
Prosecution's Evidence
- Testimonies from Ongue and Basierto detailed the events leading to Algarme's stabbing.
- Ongue reported that he saw the assailant try to pull the knife from Algarme’s back after the attack.
- The victim was transported to the hospital, where he died from massive hemorrhage due to the stab wound.
- Ongue later identified Hatton as the assailant during a police identification process, although he did not have a clear view of the attacker during the incident.
Defense of Alibi
- Hatton's defense was based on an alibi, claiming he was at the home of a friend during the time of the incident.
- His alibi was supported by the testimony of his friends, including Mrs. Laguitan, who provided