Title
People vs. Mataro y Elizaga
Case
G.R. No. 130378
Decision Date
Mar 8, 2001
Two men convicted of murder for shooting a police officer in broad daylight; alibis rejected, eyewitnesses deemed credible, and treachery established.

Case Summary (G.R. No. 136066-67)

Charges Against the Accused

Two separate informations were filed against the accused. The charges accused them of conspiring to murder SPO1 Enrique Castillo with evident premeditation, treachery, and superior strength. The prosecution aimed to demonstrate that the intent to kill was present, substantiated by eyewitness accounts of the murder.

Eyewitness Testimony

The prosecution presented two key eyewitnesses: Victor Nilo Fernandez and Reden Guzman. Fernandez testified that he observed the accused approach Castillo, followed by an exchange that ended with the shooting. Guzman corroborated this, indicating he witnessed the shooting from a passenger jeepney. Their consistent accounts formed a critical basis for the prosecution's case.

Forensic Evidence

Dr. Juan Zaldariaga, a medico-legal officer, confirmed that SPO1 Castillo sustained three gunshot wounds, observing the positions from which they could have been inflicted. The investigative officer, SPO3 Jaime Santos, highlighted the identification process, wherein the eyewitnesses identified the accused in line-ups shortly after the crime.

Defense Strategies

The defense relied on alibi and denial. Mataro claimed to be in Antipolo with witnesses during the time of the murder, while Perucho asserted he was in Aklan. However, both defenses lacked corroboration and were undermined by the chain of events presented by the prosecution.

Trial Court Decision

On January 29, 1997, the trial court ruled the defendants guilty beyond a reasonable doubt. The court underscored the credibility of eyewitnesses and the absence of any substantial evidence to support the defense's claims of alibi. The decision emphasized that the murder was executed with treachery, as the victim was surprised and defenseless during the attack.

Appeal and Legal Principles

The accused appealed the decision, arguing for their acquittal based on reasonable doubt and questioning the credibility of the witnesses. The appeal highlighted alleged inconsistencies in witness accounts regarding the vehicle used and the physical description of one accused.

Appellate Court's Findings

The appellate court confirmed that the identification of the accused was clear and unwavering, rejecting claims of inconsistencies as minor details that did not detract from the overall reliability of prosecution witnesses. Furthermore, it reaffirmed the trial court's findings concerning treachery in the manner of the attack.

Dama

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