Case Digest (G.R. No. 152205)
Facts:
The case involves Regore Baldeo as the petitioner, with the People of the Philippines as the respondent in a murder case. The events occurred on February 16, 1996, in Poblacion, Tiaong, Quezon, Philippines. An information for murder was filed against Baldeo on July 16, 1996, before the Regional Trial Court of Lucena City, specifically Branch 60. The accusation alleged that Baldeo, intending to kill and exhibiting evident premeditation and treachery, shot Luisito Caparas multiple times with a firearm, leading to Caparas' death.
The prosecution’s case relied upon witnesses including Lourdes Basilan, who was the sole eyewitness, as well as Dr. Celso Exconde, Dr. Wilma Castillo-Laroza, and others. Basilan testified that she saw Baldeo shoot Caparas at close range amidst a conversation, recalling details of the gunshots and the victim's falling motion. The medical examination confirmed multiple gunshot wounds as the cause of death. Other testimonies indicated that there were
Case Digest (G.R. No. 152205)
Facts:
- On July 16, 1996, an information for murder was filed against petitioner Regore Baldeo before the Regional Trial Court of Lucena City.
- The information alleged that on or about February 16, 1996, at Poblacion, Municipality of Tiaong, Quezon, the petitioner, with intent to kill and exhibiting evident premeditation and treachery, attacked and shot victim Luisito Caparas using a firearm of undetermined caliber.
- The prosecution alleged that the killing was sudden and unexpected, leaving the victim no opportunity to defend himself or escape.
Background and Incident
- Testimony of Lourdes Basilan (Prosecution’s Lone Eyewitness)
- Basilan, under the Witness Protection Program, testified that she witnessed Baldeo and the victim talking by the gate of Dr. Celso Exconde’s residence and clinic along Masangkay Street.
- As she passed by, she observed petitioner fire several gunshots at Caparas; she described hearing three to five successive shots, with the first gunshot striking Caparas on the forehead.
- She detailed that after the shooting, the victim fell, sustaining multiple gunshot wounds, while the petitioner casually walked by towards a parked car before speeding off.
Prosecution’s Evidence and Witness Testimonies
- Petitioner’s alibi and denial
- Baldeo asserted that at the time of the incident, he was fulfilling his duties as the barangay captain of Bgy. Lumingon, Tiaong, and as president of the Association of Barangay Captains of Tiaong, as well as a member of the Quezon Provincial Board.
- He described his morning routine on February 16, 1996, which involved driving his green Nissan to his billiard hall accompanied by his five children to collect daily income.
- He claimed to have encountered the issue involving Ernesto Caparas (the victim’s brother) and reported the incident to Barangay Captain Edring Mendoza, later visiting his lawyer and then returning home at 8:00 p.m.
- Vicente Lauro’s testimony confirmed Baldeo’s presence in San Pablo City in the early morning hours, supporting his alibi.
Defense’s Evidence and Alibi
- On March 10, 2000, the Regional Trial Court rendered its decision finding petitioner Regore Baldeo guilty beyond reasonable doubt of homicide.
- The court sentenced him to an indeterminate penalty ranging from 10 years (prision mayor in its medium period) to 17 years (reclusion temporal in its medium period).
- The court also imposed civil indemnity and damages against him for the benefit of the victim’s heirs.
- The award for attorney’s fees was rendered but later contested.
- The Court of Appeals later affirmed the trial court’s decision in its entirety, and the case was elevated to the Supreme Court via a petition for review.
Judicial Proceedings and Final Trial Outcome
- The petitioner contended that the testimony of the lone eyewitness, Lourdes Basilan, should be excluded or disregarded due to alleged inconsistencies and recantation of a prior statement regarding the assailant’s identifying mark (a scar on the right cheek).
- He further argued that the overall evidence for the prosecution was inconclusive to sustain his conviction beyond reasonable doubt, thus entitling him to acquittal.
Points Raised in the Petition for Review
Issue:
- Whether the testimony of prosecution witness Lourdes Basilan should be excluded or disregarded on the ground that it was contradictory, particularly in light of her apparent recantation regarding the assailant’s identifying scar.
- Whether the evidence presented by the prosecution was insufficient or inconclusive to establish petitioner Regore Baldeo’s guilt beyond reasonable doubt, considering the alleged inconsistencies in witness testimonies.
- Whether an accused, in circumstances where there is a lack of clear and convincing evidence of his guilt, is entitled to an acquittal regardless of the presence of alternative evidence such as an alibi or denial.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)