327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Can Two Brothers be Convicted of Murder Based Solely on
Eyewitness Accounts from the Victim's Family?
People of the Philippines v. Dante Galam and Lito Galam
G.R. No. 224222 | October 09, 2019
Facts of the Case:
In this case, Dante Galam and Lito Galam were charged with
murder for the killing of Eusebio Antolin. The incident occurred on the evening
of January 15, 2000, in Muñoz, Nueva Ecija. The Antolin family, including Mario
and Mary Jane, testified that their father, Eusebio, was having dinner with
them when they heard a commotion outside. Mario shone a flashlight and saw
Eusebio arguing with Dante and Lito. During the argument, Lito pointed a gun at
Eusebio, and after being provoked by Eusebio to shoot, Lito fired a fatal shot
into Eusebio’s chest. The brothers then fled the scene.
Prosecution witnesses further testified that days before the
incident, Dante and Lito had threatened Eusebio during a previous
confrontation, saying that they would kill him. Eusebio’s family pointed to
this history as a premeditated act of murder.
At trial, the Galam brothers pleaded not guilty. Dante
presented an alibi, claiming he was at his sister’s house at the time of the
incident, a statement corroborated by his sister and brother-in-law. Lito did
not testify. The trial court found both guilty of murder, sentencing them to reclusion
perpetua.
On appeal, the Court of Appeals upheld the conviction, but
increased the damages payable to Eusebio’s family. The case was elevated to the
Supreme Court, with the brothers arguing that the lower courts erred in their
findings and that the evidence was insufficient to prove guilt beyond a
reasonable doubt.
Primary Legal Issue:
Did the Court of Appeals err in affirming the appellants'
conviction for murder based on the eyewitness accounts from family members,
especially given the absence of forensic evidence and claims of bias?
Supreme Court's Ruling:
The Supreme Court affirmed the conviction but modified it,
ruling that the evidence did not support the finding of treachery or evident
premeditation required to classify the crime as murder. Instead, the Court held
that the Galam brothers were guilty of homicide. The Court explained that while
there was sufficient evidence to convict them for the killing, the
circumstances did not show the deliberate planning or treachery necessary to
upgrade the offense to murder. As a result, their sentence was reduced to eight
years and one day to fourteen years and eight months of imprisonment, along
with damages to be paid to the heirs of Eusebio Antolin.
Dispositive Portion of the Decision:
“Appellants Dante Galam and Lito Galam are found guilty of
homicide. They are sentenced to eight (8) years of prisión mayor as
minimum to fourteen (14) years, eight (8) months, and one (1) day of reclusión
temporal as maximum. They are further required to jointly and solidarily
pay P50,000.00 as civil indemnity, P50,000.00 as moral damages, and P50,000.00
as temperate damages. These amounts shall earn six percent (6%) interest per
annum from finality of this decision until fully paid.”
How does the reliance on eyewitness testimony, particularly
from the victim's family, influence the outcomes of criminal trials in the
absence of forensic evidence? Can personal biases of witnesses sway the court's
judgment?
Doctrines Discussed in the Case:
- Positive
Identification by Witnesses – The Supreme Court emphasized that
credible and straightforward testimony from witnesses who positively
identify the accused as the perpetrator is sufficient to convict, even in
the absence of forensic evidence.
- Treachery
and Evident Premeditation – For these to qualify a crime as murder, it
must be shown that the assailant deliberately ensured the victim could not
defend themselves and that there was clear intent and planning to commit
the crime. The Court found that neither of these circumstances was present
in this case.
- Alibi
as a Defense – The Court reiterated that alibi is a weak defense,
especially when the accused is positively identified by eyewitnesses and
when the alibi fails to prove it was impossible for the accused to be at
the crime scene.
- Conspiracy
– Conspiracy exists when two or more persons agree to commit a felony and
carry it out. In this case, the coordinated actions of Dante and Lito
before, during, and after the crime showed a unity of intent to kill the
victim, holding both accountable for the crime.
- Credibility
of Witnesses from the Victim’s Family – The Court rejected the
defense's argument that the testimonies of Mario and Mary Jane, as
children of the victim, were biased. It emphasized that close
relationships between witnesses and victims do not automatically negate
credibility. Family members often testify to seek justice, and in this
case, their testimonies were found to be credible, straightforward, and
aligned with the medical findings.
- Frontal
Attack Does Not Automatically Mean Treachery – The Supreme Court pointed
out that while the attack was sudden, it was not carried out in a manner
that ensured the victim was defenseless or caught completely by surprise.
A challenge from the victim to shoot him negated the existence of
treachery.
- Homicide
Instead of Murder – Since treachery and evident premeditation were not
proven, the crime was downgraded from murder to homicide. The lack of
aggravating circumstances meant that the penalties for homicide under
Article 249 of the Revised Penal Code applied, which carries a lower
penalty than murder.
Classification of the Case:
This case falls under Criminal Law as it deals with
the criminal prosecution of individuals charged with murder, ultimately
resulting in a conviction for homicide.
From <https://chatgpt.com/g/g-ipZC0xKZ1-case-digest/c/66eeb804-68f4-800a-b093-5adbba4762d1>
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🎓 In this jurisprudence
discussion, we explore People of the Philippines v. Dante Galam and Lito
Galam, G.R. No. 224222, promulgated on October 9, 2019. This
content focuses on key doctrines and rulings aimed at helping law students
and bar examinees recall essential criminal law principles, especially
concerning homicide, witness credibility, and qualifying circumstances like treachery
and evident premeditation.
The case arose from the killing of Eusebio Antolin,
allegedly by Dante and Lito Galam, following a heated altercation.
Eyewitnesses—Eusebio’s children—testified against the Galam brothers. The RTC
and CA convicted them of murder, but the Supreme Court downgraded the
conviction to homicide, citing the lack of treachery and evident
premeditation.
🧠 Should emotional family
eyewitnesses always be considered credible when identifying the accused?
📘 NATURE OF THE CASE:
Criminal Law – Homicide (Originally charged as Murder)
📌 CASE DETAILS:
- Case
Title: People of the Philippines v. Dante Galam and Lito Galam
- Parties:
Plaintiff-Appellee: People of the Philippines | Accused-Appellants: Dante
and Lito Galam
- G.R.
No.: 224222
- Date
of Promulgation: October 9, 2019
📚 10 IMPORTANT DOCTRINES
- Positive
Identification Prevails Over Alibi
Credible eyewitness testimony, even from relatives, is stronger than an uncorroborated alibi.
Cited: p. 42-43, TSN July 3, 2000 & November 12, 2003 - Family
Members Can Be Credible Witnesses
Relationship to the victim doesn’t automatically render testimony biased if it’s clear, consistent, and aligned with other evidence.
Cited: People v. Saltarin, p. 46 - Treachery
Requires Deliberate Means to Prevent Defense
The Court found no treachery since the victim was warned and provoked the attacker.
Cited: p. 63-64, People v. Pilpa - No
Evident Premeditation Without Overt Acts
Threats made days prior were not accompanied by acts showing a clung determination to kill.
Cited: p. 67, People v. Sarmiento - Conspiracy
Need Not Be Express—Can Be Inferred
Coordinated actions before, during, and after the crime imply conspiracy.
Cited: p. 60, People v. Manes - Use
of a Gun Doesn’t Automatically Mean Treachery
Frontal attacks using firearms don’t inherently show treacherous intent.
Cited: p. 65, People v. Paracale - Medical
Evidence Isn’t Invalid Due to Embalming
Post-embalming autopsies can still confirm cause of death when consistent with eyewitness accounts.
Cited: p. 48, People v. Gallego - Homicide
vs. Murder: Burden of Proving Qualifying Circumstances
If treachery and premeditation aren’t proven beyond reasonable doubt, murder is downgraded to homicide.
Cited: p. 71, Article 249, RPC - Denial
Is Worthless Against Positive Identification
Denial, especially without corroboration, is the weakest defense in criminal law.
Cited: p. 54, People v. Galicia - Conspiracy
Makes All Equally Liable
Where conspiracy is proven, all conspirators are liable as co-principals even if only one performed the killing.
Cited: p. 60-61, Article 8, RPC
❓ FREQUENTLY ASKED QUESTIONS:
Q1: What crime were the accused finally convicted of?
A: Homicide, not murder, due to lack of treachery and
evident premeditation.
Q2: Were the eyewitnesses related to the victim?
A: Yes, his children—but their testimony was deemed credible
and consistent.
Q3: What sentence was imposed by the Supreme Court?
A: 8 years and 1 day to 14 years, 8 months, and 1 day of
imprisonment.
Q4: What damages were awarded?
A: ₱50,000 civil indemnity, ₱50,000 moral damages, and
₱50,000 temperate damages.
Q5: Can a case still be proven without forensic evidence?
A: Yes, credible and consistent eyewitness testimony can
suffice.
📢 DISCLAIMER:
This content is for educational purposes only and
does not guarantee legal infallibility. It was made using premium AI
tools to assist Philippine law students and bar examinees.
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From <https://chatgpt.com/g/g-ipZC0xKZ1-case-digest/c/66eeb804-68f4-800a-b093-5adbba4762d1>
🎓 Welcome, future abogados! This quizzer is based on the landmark criminal law case of People of the Philippines v. Dante Galam and Lito Galam, G.R. No. 224222, promulgated on October 9, 2019. This case involves the fatal shooting of Eusebio Antolin, where the primary issue centered on whether the accused should be convicted of murder or homicide. Initially convicted of murder by the RTC and Court of Appeals, the Supreme Court downgraded the conviction to homicide, ruling that treachery and evident premeditation were not sufficiently proven.
This quizzer is designed to test your higher-order
thinking skills (HOTS) using key facts and doctrines derived from the case.
These questions are especially helpful for law students and bar takers
reviewing criminal law jurisprudence.
✅ Answer key will be provided
at the end of the video. Let’s begin!
🔍 QUIZZER: 10 EASY
DIFFICULTY HOTS MULTIPLE CHOICE QUESTIONS
1. What was the final conviction of the accused in
the case?
A. Attempted homicide
B. Murder
C. Homicide
D. Reckless imprudence resulting in homicide
2. Why did the Supreme Court rule out the presence of
treachery?
A. The attack was done in public
B. The victim had time to flee
C. The attack was frontal and preceded by an argument
D. The weapon used was not deadly enough
3. Which statement best explains why evident
premeditation was not appreciated?
A. The accused denied making any threats
B. No clear act showed that the threat was followed through
C. The gun used was not pre-owned
D. The shooting was accidental
4. Why was the testimony of the victim’s children
upheld by the Court?
A. They were the only witnesses available
B. They testified despite having memory lapses
C. Their relationship to the victim enhanced their
credibility
D. Their accounts were consistent, clear, and corroborated
5. Which defense was raised by one of the accused?
A. Mistake of fact
B. Alibi
C. Self-defense
D. Involuntary intoxication
6. What was the main reason the defense of alibi was
rejected?
A. It was not supported by any testimony
B. The accused was too far from the crime scene
C. It did not show physical impossibility to be at the crime
scene
D. It was accepted but outweighed by motive
7. What role did the medico-legal report play in the
case?
A. It proved that the victim died of stabbing
B. It contradicted the eyewitness account
C. It confirmed that the cause of death aligned with the
eyewitness testimony
D. It was dismissed because the body had been embalmed
8. How did the Court view the accused's failure to
present a defense witness?
A. As a procedural lapse
B. As proof of innocence
C. As a waiver of the right to be heard
D. As failure to rebut the prosecution’s case
9. Which of the following best describes the presence
of conspiracy between the accused?
A. One accused admitted to planning the crime
B. They acted together with shared intent before, during,
and after the crime
C. They had different motives and actions
D. One ran away while the other stayed
10. What was the total amount of damages finally
awarded by the Supreme Court?
A. ₱100,000
B. ₱180,000
C. ₱150,000
D. ₱200,000
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