G.R. No. 120282 April 20, 1998
People of the Philippines, plaintiff-appellee, vs. Robert Castillo y Mones, accused-appellant.

FACTS

An amended Information charged Robert Castillo y Mones with the murder of Antonio Dometita on May 25, 1993, in Quezon City, qualified by evident premeditation, use of superior strength, and treachery. Upon arraignment, the accused pleaded not guilty. The prosecution presented eyewitness Eulogio Velasco, the floor manager of Cola Pubhouse, who testified that around 1:00 a.m., as the victim exited the pubhouse and was about an arm’s length away, the accused suddenly appeared and stabbed Dometita on the left chest with a fan knife. When the victim pleaded for help, the accused stabbed him again on the left arm. Velasco intervened by placing a chair between them and shouted for the victim to run. The victim ran towards EDSA with the accused in pursuit. The victim’s body was later found. Dr. Bienvenido Muñoz, the medico-legal officer, confirmed the cause of death was a stab wound on the left chest and noted other wounds indicating resistance. Prosecution witness Melinda Mercado testified she saw the accused walking away from the scene carrying a bladed weapon. The defense presented an alibi, supported by the testimonies of the accused’s mother and a neighbor, claiming he was not at the scene. Defense witness Edilberto Marcelino, a tricycle driver, testified he saw two people ganging up on a third person in an alley near the Iglesia ni Cristo Church, and he reported this to the Barangay Tanod, as reflected in a barangay blotter (Exhibit “2”). The Regional Trial Court convicted the accused of murder, sentenced him to reclusion perpetua, and ordered him to pay damages.

ISSUE

1. Whether the trial court erred in its assessment of the credibility of the witnesses and their testimonies.
2. Whether the trial judge exhibited bias and partiality by actively participating in the examination of witnesses.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the assailed Decision with modification regarding the award of damages. The trial court’s factual findings and credibility assessments are entitled to great weight and are conclusive, barring arbitrariness. The testimony of prosecution eyewitness Eulogio Velasco was clear, unequivocal, and consistent with the medical findings. His positive identification of the accused as the perpetrator prevails over the defense of alibi and the claim of a different incident involving two assailants. The barangay blotter presented by the defense did not conclusively prove that the reported mauling incident involved the same victim. The trial judge’s act of propounding clarificatory questions to witnesses to ferret out the truth is within his authority and does not indicate bias or partiality. A judge is not an idle arbiter and may examine witnesses to clarify points. The killing was qualified by treachery, as the attack was sudden and unexpected, giving the victim no opportunity to defend himself. The award of actual and moral damages was deleted for lack of factual basis. Costs were imposed against the appellant.