G.R. No. L-31594 - People vs. Puno y Ma

This case involves Celestino Marturillas, a former Barangay Captain of Gatungan, Bunawan District, Davao City, who was charged with homicide for the killing of Artemio Pantinople on November 4, 1998.
The criminal case was originally tried in the Regional Trial Court (RTC) of Davao City, Branch 10, which found Marturillas guilty of homicide. The Court of Appeals (CA) affirmed the RTC decision, with modifications regarding the award of damages.

On the evening of November 4, 1998, a shooting occurred in Barangay Gatungan, where Artemio Pantinople was fatally wounded by a gunshot.
Eyewitnesses testified that at approximately 6:00–7:30 p.m., a series of events unfolded: Lito Santos, a neighbor, heard a gunshot, saw smoke and fire from a gun muzzle, and subsequently observed Artemio Pantinople staggering and later collapsing.
Concurrently, Ernita Pantinople, the victim’s wife, was present at her home when she heard the gunshot and then saw Marturillas fleeing the scene, wearing a black jacket and camouflage pants while carrying an M-14 rifle.

Testimonies from multiple witnesses (including Lito Santos, Ernita Pantinople, PO2 Mariano Operario, Alicia Pantinople, and a medico-legal officer, Dr. Danilo Ledesma) established the sequence of events.
Witnesses confirmed that after the shooting, the victim reportedly cried out “Help me p’re, I was shot by the captain,” thereby implicating Marturillas.
Physical evidence included the findings of an autopsy by Dr. Ledesma, which documented the entry and exit wounds caused by a gunshot, and observations on the trajectory and distance indicating that the assailant fired from a lower position.
The crime scene was illuminated by a full moon and two fluorescent lamps from a nearby store, which aided in the identification of the fleeing suspect.

Marturillas claimed that he was awakened around 8:30 p.m. by his wife and barangay kagawads regarding the shooting incident.
He and his companions, including other SCAA members, went to the scene not to commit the crime but to render assistance and investigate, only to be met with hostility from the victim’s family.
Upon returning home, he immediately alerted the authorities by instructing one of his companions to contact the police.
At the police station, he surrendered his M-14 rifle and live ammunition, and a paraffin test was conducted on his hands, yielding negative results for gunpowder nitrates.

The Bunawan Police Station’s investigation, assisted by other law enforcement personnel, led to the filing of a Complaint by PO2 Operario based on the sworn affidavits of key witnesses.
The prosecution presented evidences including the dying declaration of the victim, corroborative testimonies of neighbors, and physical evidence from the crime scene.
Despite the defense’s arguments regarding inconsistencies in witness affidavits and Marturillas’ alibi, the trial and appellate courts maintained that the factual findings were supported by reliable and cogent evidence.

The CA affirmed the RTC’s award of actual, temperate, and moral damages, though with modifications such as a reduction of moral damages from the RTC award to conform with prevailing jurisprudence.
The award included indemnity for the heirs of the victim and compensation for funeral, burial costs, and loss of earning capacity.

Whether the identification of Marturillas by the prosecution witnesses (particularly Ernita Pantinople) was reliable despite claims of poor visibility and distance.
Whether the assertions, including the victim’s dying declaration (“Help me p’re, I was shot by the captain”), are admissible and credible as part of the res gestae.

Whether the Court of Appeals erred by effectively shifting the burden of proof onto Marturillas by emphasizing the weaknesses of his defenses (denial and alibi).
Whether the negative findings of the paraffin test are conclusive exonerative evidence.

Whether alleged inconsistencies between Ernita Pantinople’s affidavit and her testimony affect her identification of Marturillas.
Whether Marturillas’ alibi (the claim of having been ordered to investigate the scene and subsequently alert the police) is plausible given the proximity of the crime scene to his residence.

Whether, taken in its entirety, the circumstantial and direct evidence provided by the prosecution is sufficient to establish Marturillas’ guilt beyond reasonable doubt.
Whether the victim’s dying declaration, corroborated by eyewitness testimonies, is reliable evidence identifying the assailant.