G.R. No. 240542 - People vs. Baltazar Achay, Jr. y Docil

Baltazar Achay, Jr. was charged in four separate Informations for different crimes related to incidents on or about September 6, 2013, in Manila, Philippines.
The crimes included violation of Section 10(a) of Republic Act No. 7610 (Special Protection of Children), two counts of Attempted Murder, Slight Physical Injuries, Less Serious Physical Injuries, and Murder.

Around 9:15 a.m., Chairperson Rolando Reyes, his wife Marilou, and other persons were conversing inside the barangay hall in Balut, Tondo, Manila.
Achay entered armed with a .45 caliber pistol and shot Chairperson Rolando twice, hitting his neck and cheek. One bullet went through Chairperson Rolando’s neck and hit Marilou’s right foot.
Achay then fled the scene.
About five to ten minutes later, Achay confronted Juanito Fausto, Jr. and shot him in the right calf. The bullet exited and grazed the head of two-year-old Adrian Dagulo, who was nearby.

Adrian Dagulo sustained a positive laceration on the frontal area, healing in less than nine days.
Juanito Fausto suffered a gunshot wound on the back of his lower left leg, with a healing duration of nine days.
Chairperson Rolando was brought to the hospital but was not revived.
Marilou was treated for the embedded bullet in her foot and confined for a day.

Police officers received a report about a man with a gun at Building 21, Permanent Housing, Balut, Tondo.
Police saw Achay with a gun tucked in his waist, frisked him, and seized the firearm and a magazine.
He was arrested and informed of his constitutional rights.

Achay denied the charges; claimed alibi that he was at home with his common-law wife and other relatives from September 6 to 8, 2013.
Claimed illegal arrest and torture to extract a confession.
Defense witnesses corroborated his alibi.
The Regional Trial Court acquitted Achay of more serious charges but convicted him of Slight Physical Injuries, Less Serious Physical Injuries, Attempted Homicide, and Murder.
The court found the positive identification of Achay by prosecution witnesses more credible than his alibi.
Treachery was found in the killing of Chairperson Rolando, but evident premeditation was not established.

Affirmed the trial court’s findings except as to Fausto’s case, where it upgraded the conviction from Slight Physical Injuries to Attempted Homicide.
Upheld the conviction for Murder, with modifications to the damages awarded.
Rejected Achay’s claim of illegal arrest, holding that the eyewitness testimonies established guilt regardless.

Issues raised included the validity of the prosecution’s evidence, the sufficiency of identification, the lawfulness of the warrantless arrest, and whether treachery was present in the murder.
Both parties elected not to file supplemental briefs but adopted previous pleadings.

Whether the prosecution proved beyond reasonable doubt that Baltazar Achay committed the crimes charged against him.
Whether the warrantless arrest of Baltazar Achay was lawful.