Prepared by: Angelyne M. Chua, 1-D 1

PEOPLE v. CASTILLO G.R. No. 120282 April 20, 1998 Aspects of the Proceedings (Art. III, Sec. I) FACTS: On December 23, 1994, Robert Castillo y Mones was convicted for the murder of Antonio Dometita by the Regional Trial Court of Quezon City, Branch 88. In the present case, Castillo appeals this decision, questioning the trial judge’s partiality in favor of the prosecution by his participation in questioning of witnesses, as well as his assessment of the credibility of the witnesses. The prosecution and Castillo’s version of the events leading to the murder differ greatly. Witnesses, Eulogio Velasco and Melinda Mercado, related the prosecution’s version of the events. Velasco was the floor manager of the Cola Pubhouse along EDSA, Project 7, Veteran’s Village, Quezon City where the victim, Dometita was a customer. On the day of the murder, May 25, 1993, Velasco was sitting outside talking to a coworker, Dorie, when Dometita came out of the pub house. The victim was “about an armslength” from Velasco when Castillo suddenly appeared and stabbed Dometita in the chest and then on the left hand. Velasco tried to help by placing a bench to block Castillo’s way and yelled at Dometita to run. The victim ran but Castillo followed him. Velasco eventually heard that Dometita was dead. This witness account was supplemented by another customer, Mercado’s, story. She said that after Dorie came inside the pub, she heard Velasco yelling that Dometita was stabbed. She went out the pub and saw Castillo walking away with the weapon. Furthermore, the prosecution witnesses’ accounts were supported by the medical findings of autopsy examiner, Dr. Munoz. In contrast, the defense’s witness was taxi driver, Edilberto Marcelino. He said that he had witness a stabbing/mauling incident on a side street near Iglesia ni Cristo Church, where Dometita’s body was found. He said two men were ganging up on a third. He identified that none of the attackers was Castillo as he was very familiar with the accused and none looked like him [Castillo.] The court gave more weight to the testimonies of the prosecutor’s witnesses as the defense witness was twenty-five meters away and the place was not lighted. He was also driving his tricycle so it may be possible that he would not recognize the victims and the attackers. It was on these testimonies that Castillo was convicted. But, Castillo is now appealing the decision as the judge lead questions for the prosecution, showing bias for the prosecution against the defense. Relating to the Constitutional Law II topic of due process and equal protection of laws, Castillo is alleging impairment of his right to due process as the judge was biased and already decided to side with the prosecution. [Restatement/Summary] ISSUES: 1. Whether or not the accused, Castillo, was deprived of due process of law because the RTC judge gave

skewed observations on the credibility of the defense witness.

2. Whether or not the accused, Castillo, was deprived of due process of law because of the RTC judge’s partiality against the defense.

Prepared by: Angelyne M. Chua, 1-D 2

HELD: 1. No.

As the RTC has the opportunity to personally observe the behavior and demeanor witnesses in the

stand, its assessment of credibility of the witnesses are entitled great weight and may be binding and conclusive in the SC. As a rule, the SC is not a trier of facts and the findings of the lower courts are binding upon them absent arbitrariness and oversight of some fact. In this case, the accused failed to provide evidence of such arbitrariness for the Court to re-try facts.

Also, due to the detailed account of the prosecutor’s witnesses, as contrast to the vague testimony of

the defense, the RTC did not commit an error in giving more weight to the prosecution’s account of the events.

The accused’s assertion that Dometita would’ve died before reaching the alley where he was found if

he [Castillo] had stabbed him as the prosecution stated as by medical records, the victim’s lungs and heart were impaled. Dr. Munoz rejected this idea as the victim was struck in the thick portion of the heart. The doctor believes that he [Dometita] would have survived enough to reach the side alley where he was found. 2. No.

The accused alleges that the trial judge was biased as he was leading-questions which should’ve been asked by the prosecution. But the Court rules that it was a judge’s prerogative to ask questions to reveal the truth. From the transcripts, the SC found the questions asked by the judge were not biased but simply clarificatory.

Furthermore, allegations of bias by RTC judges must be received by the Court, in caution. In this

case, the accused did not demonstrate how he was prejudiced by the RTC judge’s questions. Because, the SC observed that even without these questions, Castillo would still be convicted.