GR 132718; (October, 2001) (Digest)
G.R. No. 132718 ; October 5, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOSE CASTILLON III, accused-appellant.
FACTS
On September 5, 1996, Felipe Caro, a deliveryman, was shot and killed shortly after leaving his office in Iloilo City carrying a knapsack containing company money. Eyewitnesses testified to the events: tricycle driver Melchor Latuna saw accused-appellant Jose Castillon III grappling with the victim before hearing a gunshot and seeing Castillon tuck a gun at his waist. Another driver, Francisco Martinez, saw Castillon standing near the fallen victim, also tucking a gun, before fleeing. A third driver, Renato Deraco, testified that Castillon boarded his pedicab, transferred a bundle of money between bags, and threatened him. The police later arrested Castillon, who was identified in a lineup.
The defense presented alibi witnesses who claimed Castillon was in his barangay the entire day. A forensic chemist also testified that paraffin tests on Castillon were negative for gunpowder nitrates. The Regional Trial Court convicted Castillon of robbery with homicide, sentencing him to reclusion perpetua and ordering him to pay damages. Castillon appealed, challenging witness credibility, the sufficiency of evidence, the negative paraffin test, and the legality of his warrantless arrest.
ISSUE
The core issue is whether the prosecution proved Castillon’s guilt for robbery with homicide beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The positive identification by credible eyewitnesses prevails over alibi and denial. The Court found no ill motive for the witnesses to falsely accuse Castillon, and their testimonies were consistent and detailed. The defense of alibi, inherently weak, was not credible as the barangay was not an impossible distance from the crime scene. The negative paraffin test does not exculpate the accused, as such tests are unreliable, especially if the suspect had washed his hands or used a gloved hand. The Court also held that any irregularity in the warrantless arrest was waived when Castillon voluntarily submitted to the court’s jurisdiction by entering a plea.
The penalty of reclusion perpetua was proper under Article 294 of the Revised Penal Code, as amended. The Court modified the damages: the death indemnity of P50,000.00 was affirmed; moral damages were increased to P50,000.00; and actual damages were reduced to P17,925.00, based on receipts substantiating expenses for the victim’s burial and wake.