Case Digest (G.R. No. 215732)
Facts:
People of the Philippines v. Christopher Badillos, G.R. No. 215732, June 06, 2018, Supreme Court Third Division, Martires, J., writing for the Court. The prosecution (plaintiff-appellee) charged Christopher Badillos (accused-appellant) and a John Doe with the August 11, 2007 killing of Alex H. Gregory in Bocaue and filed an Information on November 5, 2007. Christopher was arraigned on February 26, 2008 and pleaded not guilty; trial on the merits followed.
At trial the prosecution presented three witnesses—Domingo C. Gregory (an eyewitness), Jonathan Gregory (the victim’s brother), and Elsa H. Gregory (the victim’s mother)—and offered medico-legal evidence establishing a stab wound to the left pectoral region as the cause of death. Domingo testified that he and Alex were ambushed while walking home; Christopher allegedly appeared armed with a blade and an unidentified companion with a wooden club. Jonathan arrived later and testified that Alex, in extremis, named “Boyet” (Christopher) as his assailant. The defense dispensed with some prosecution witnesses by stipulation.
The defense presented Christopher and two alibi witnesses—his uncle Alex Rapsing and cousin Myrna Acedillo—who testified Christopher left a fiesta earlier and traveled to Valenzuela where he stayed the night, denying involvement in the killing.
The Regional Trial Court, Branch 78, Malolos, Bulacan, by decision dated September 21, 2012, found Christopher guilty of murder under Article 248 of the Revised Penal Code, applied the aggravating circumstance of treachery, and imposed reclusion perpetua plus civil indemnity, moral damages and funeral expenses. Christopher appealed to the Court of Appeals (CA-G.R. CR-H.C. No. 05864), which on April 23,...(Subscriber-Only)
Issues:
- Did Alex’s utterance to his brother qualify as a dying declaration admissible as such, or was it admissible only as part of res gestae?
- Was the accused’s guilt proven beyond reasonable doubt despite his alibi and the defense evidence?
- Did the facts establish treachery sufficient to elevate the killing to murder under Article 24...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)