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 judges 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 Castillos version of the events leading to the murder differ greatly.
Witnesses, Eulogio Velasco and Melinda Mercado, related the prosecutions version of the events.
Velasco was the floor manager of the Cola Pubhouse along EDSA, Project 7, Veterans 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 Castillos 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, Mercados, 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 defenses 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 Dometitas 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 prosecutors 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 judges
partiality against the defense.

Prepared by: Angelyne M. Chua, 1-D

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 prosecutors witnesses, as contrast to the vague testimony of
the defense, the RTC did not commit an error in giving more weight to the prosecutions account of the
events.
The accuseds assertion that Dometita wouldve died before reaching the alley where he was found if
he [Castillo] had stabbed him as the prosecution stated as by medical records, the victims 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 shouldve been
asked by the prosecution. But the Court rules that it was a judges 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 judges questions. Because, the
SC observed that even without these questions, Castillo would still be convicted.

Prepared by: Angelyne M. Chua, 1-D