G.R. No. 118912; May 28, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. QUINTIN CASTILLO y MASANGKAY and RICARDO CASTILLO y ARCE, appellants.

FACTS

On April 8, 1982, after a drinking session, an altercation occurred between the victim, Manolito Hernandez, and Juanito Cusi, during which the victim hit Juanito with a stone. The victim’s father, Buenaventura, left to bring Juanito to the hospital, leaving the victim with appellants Quintin and Ricardo Castillo. Buenaventura later saw the appellants taking the victim home. Concerned, he instructed his 13-year-old son, Romeo, to fetch the victim. Romeo located the victim and, from a distance of six meters with a flashlight, witnessed the appellants attacking the victim. He saw Quintin stabbing the motionless victim with a shiny object while Ricardo was astride the victim, beating his head with a stone. Romeo shouted, causing the appellants to turn towards him, after which he fled.
The defense presented a different version, claiming they left the victim upon his request and later heard him shout provocatively. They alleged they met three drunk men and pointed them towards the victim’s direction before heading home. A defense witness, Romulo Cusi, also testified that Romeo could not have witnessed the killing as he rode to the hospital with them, contradicting the prosecution’s timeline.

ISSUE

The core issue is whether the prosecution proved the guilt of the appellants for the crime of Murder beyond reasonable doubt, particularly in light of the credibility of the eyewitness account and the presence of treachery.

RULING

The Supreme Court affirmed the conviction of appellant Ricardo Castillo for Murder, modifying the penalty to reclusion perpetua and awarding damages. The Court found the testimony of eyewitness Romeo Hernandez credible and sufficient to establish guilt. Romeo’s account was clear, detailed, and consistent, and his minor age did not detract from its reliability, as the Court has held that the testimonies of young witnesses can be credible if given in a straightforward manner. His immediate report to his cousin Cosme, who then found the victim’s body, corroborated his story.
The Court rejected the defense of alibi and denial, which were inherently weak and could not prevail over the positive identification by an eyewitness. The medical findings, which indicated wounds caused by a sharp instrument and a hard blunt object, were consistent with Romeo’s account of a stabbing and a beating with a stone. The qualifying circumstance of treachery was correctly appreciated because the attack was sudden and deliberate, rendering the victim defenseless as he was already being restrained and assaulted. The Court sustained the lower courts’ findings, emphasizing that factual assessments, especially on witness credibility, are generally binding on appeal.