Title
Supreme Court
People vs. Vasquez
Case
G.R. No. 102366
Decision Date
Oct 3, 1997
Primo Dollete drowned in 1968; Vasquez brothers accused of murder. Prosecution's case lacked physical evidence, witnesses had disputes. Supreme Court acquitted due to insufficient proof, favoring defense's accidental drowning claim.

Case Summary (G.R. No. 102366)

Allegations and Initial Proceedings

The Vasquez brothers were charged with the murder of Primo Dollete, alleged to have occurred when they attacked Dollete and subsequently drowned him in a river. The charge stemmed from events where the brothers reportedly assaulted Dollete and dragged him to the river. Their defense maintained that Dollete's death was accidental, resulting from drowning due to an incident unrelated to any criminal act.

Delay in Prosecution

The prosecution faced significant delays, spanning nearly 18 years, largely attributed to missing records and administrative hurdles during prior judicial reviews. Various judges presided over the initial complaint and hearings; however, the case stalled before reaching the trial court until a new judge facilitated its progression in January 1986.

Trial Court Findings

Upon trial, the Regional Trial Court in Roxas City concluded that the evidence against the appellants adequately established their guilt beyond reasonable doubt. The court emphasized the witnesses' testimonies that described the sequence of events leading to Dollete's death. The trial was marked by contrasting narratives from witness accounts versus the physical evidence presented during the post-mortem examination, resulting in the conviction of the brothers.

Prosecution’s Evidence and Witness Testimonies

Witnesses for the prosecution provided details of the alleged attack, stating that Hector and Renato Vasquez assaulted Dollete while he was urinating, following which they dragged him to the river, where they submerged him. Key testimonies indicated that witnesses had positively identified both appellants as the assailants.

Defense’s Position

The defense asserted an alibi, claiming both accused were in Iloilo City at the time of the incident and not present in Panit-an. They also challenged the credibility of the prosecution witnesses, presenting evidence that suggested Dollete's death was the result of an accident rather than a homicide. The defense highlighted inconsistencies among witness testimonies and pointed to the lack of significant physical injuries on Dollete's body that would correlate with the claims of violent assault prior to his drowning.

Post-Mortem Findings

A post-mortem examination revealed that Dollete died from asphyxia due to drowning; however, no substantial external injuries indicative of an assault, such as bruises or trauma common with a physical fight, were found. The medical findings were pivotal in undermining the prosecution’s narrative, as they did not support the aggressive assault described by numerous witnesses.

Appeals and Final Judgment

The defense appealed the conviction, citing multiple errors committed by the trial court, includi

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