Title
Baldeo vs. People
Case
G.R. No. 152205
Decision Date
Feb 5, 2004
Baldeo convicted of homicide after eyewitness testimony, despite recantation, overruled his alibi; damages increased for victim’s heirs.
Font Size:

Case Digest (G.R. No. 152205)

Facts:

    Background and Incident

    • 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.

    Prosecution’s Evidence and Witness Testimonies

    • 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.

    Defense’s Evidence and Alibi

    • 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.

    Judicial Proceedings and Final Trial Outcome

    • 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.

    Points Raised in the Petition for Review

    • 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.

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)

Analyze Cases Smarter, Faster
Jur is an AI-powered legal research tool in the Philippines with case digests and full jurisprudence. AI summaries highlight key points but might skip important details or context. Always check the full text for accuracy.