G.R. No. 254747 - People vs. Angeles y Manlapaz

The case arises from an Information charging accused-appellant Rod Angeles y Manlapaz, alias “Uro,” along with his co-accused and other alleged assailants for the killing of Joey Puro Toong in Quezon City on July 15, 2009.
The Information alleges that a group of about seven to eight male teenagers conspired, confederated, and mutually assisted one another in the commission of murder by mauling and stabbing the victim.
The killing was qualified by the circumstance of abuse of superior strength, as the assailants planned the crime, adopted means and methods of execution, and used excessive force to overcome the victim’s defense.

Witness testimonies, particularly that of Philip Baltes and the victim’s mother, Anacleta Toong, corroborated the events on the night of July 15, 2009.

Baltes’s initial account stated that while waiting at the Bread Line Bakery in Brgy. Bagbag, Novaliches, he observed the victim waiting for his brother.
He witnessed a group of teenagers attacking the victim, causing him to fall and later be dragged by an accomplice named Reymark.

The eyewitness specifically identified accused-appellant when the victim was dragged to the side of the bakery.

Baltes detailed how five of the assailants beat the victim for about three minutes, and accused-appellant stabbed the victim in the chest with a double-edged knife.
Additional graphic descriptions included another assailant, “Bebe,” who impaled the victim with an ice pick.

Subsequent to the incident, Baltes attempted to assist the victim but was prevented by his mother.
Witnesses from the police, such as Police Officer Modestino G. Juanson, also testified to aspects of the incident immediately after it occurred.

Accused-appellant denied the charge, claiming he was in Tarlac City at the time of the incident, despite being a resident of Novaliches, Quezon City.

He presented documents (a barangay certification) to substantiate his claim of residing in Tarlac between 2008 and 2010.

His co-accused, Ronnel Dela Vega, also denied involvement by stating he was employed as a pedicab driver and did not know the victim or his family.
During the trial, Baltes initially testified for the prosecution by identifying accused-appellant as one of the assailants.

His direct examination provided a clear and graphic account of the stabbing and mauling of the victim.

In his recantation, he claimed that there had been a misunderstanding and that both accused-appellant and Ronnel were innocent.
However, the recantation was made seven years after his initial testimony and appeared jittery and inconsistent, raising questions on its credibility.

Accused-appellant also argued that the recantation of Baltes should have exonerated him and that his defense of denial and alibi was not properly considered.

The Regional Trial Court (RTC) of Quezon City rendered a decision on September 15, 2017:

It found accused-appellant guilty beyond reasonable doubt of Murder under Article 248 of the Revised Penal Code (RPC) with the aggravating circumstance of abuse of superior strength.
It acquitted co-accused Ronnel for insufficiency of evidence.
The sentence imposed upon accused-appellant was reclusion perpetua.

The Court of Appeals (CA) affirmed the RTC’s ruling in its Decision dated February 10, 2020.

The CA dismissed the appeal, underscoring that the evidence, particularly the consistent initial testimony of Baltes, sufficiently established the guilt of accused-appellant.
The appellate court gave greater credence to Baltes’s earlier spontaneous and detailed testimony rather than his later recantation.

Accused-appellant filed an appeal to assail the findings on three main issues (addressed below), while the Office of the Solicitor General (OSG) joined in support of the prosecution’s findings.

Whether the Court of Appeals erred in upholding the conviction of accused-appellant for Murder despite the later recantation by the prosecution’s sole eyewitness, Baltes.
Whether the CA improperly relied on the identification of accused-appellant as one of the assailants given the alleged doubts stemming from the recantation and inconsistent identification evidence.
Whether the trial courts erred in disregarding the accused-appellant’s defenses of denial and alibi, particularly his claim of being in Tarlac City at the time of the murder and the failure to substantiate these defenses with clear and convincing evidence.