G.R. No. L-2390 - People vs. Baldera

On December 23, 1947, at about 4 a.m., a Casa Manila bus, carrying numerous passengers from Batangas bound for Manila, was held up on the highway in barrio Calansayan, San Jose, Batangas.
The robbery was committed by a group of five or six armed men who attacked the bus with a barrage of gunfire, resulting in several passengers being wounded.
Among the wounded was Jose Cabrera, who later died from his injuries, and other victims including Jose Pastor and Francisco Mendoza who sustained injuries of varying degrees.

Pedro Baldera, identified later as one of the armed men, was involved in the incident. He was armed with a .45 caliber pistol and reportedly fired a shot that triggered the ensuing hail of bullets from multiple directions.
After the gunfire ceased, Baldera boarded the bus, armed and threatening the passengers, and proceeded to rob them. He relieved Ponciana Villena of P90, Jose Pastor of P34, and Francisco Mendoza of P3.
The bus driver subsequently diverted the bus to the municipal building of San Jose, where the incident was reported, while the wounded victims were transported to the hospital.

Appellant Baldera was arrested in connection with the theft of a radio in Batangas shortly after the robbery. His physical features corresponded with the description provided by the bus passengers, linking him to the hold-up.
A written confession was made by Baldera before the justice of the peace wherein he admitted his participation in the robbery, particularly the act of boarding the bus with a pistol and robbing Ponciana Villena.
Testimony by Ponciana Villena at trial directly identified Baldera as the assailant who relieved her of her money at gunpoint.
Other passengers corroborated the resemblance of Baldera to the man who participated in the hold-up.

Baldera denied participation in the crime, asserting that he had spent the night at a house of prostitution in Batangas, where he was employed by the prostitutes drawing water. This alibi, however, was unsupported by any independent evidence.
His counsel argued the inadmissibility of his confession on the ground that it was made under a promise of protection from his co-accused and for use as a government witness.
Counsel also contended that the proper characterization of the crime should not have included “robbery in band”, having questioned the sufficiency of evidence regarding the number of conspirators involved.

Whether the evidence, particularly the victim’s identification and Baldera’s confession, conclusively proved beyond a reasonable doubt that Baldera was one of the perpetrators of the robbery, homicide, and physical injuries.
How reliable and credible were the testimonies, especially that of Ponciana Villena, in linking Baldera to the commission of the crime?

The issue of whether the appellant’s confession, allegedly made under a promise of protection and as part of a government agreement, should be admissible as evidence against him.
Whether any claim of coercion or intimidation in securing the confession undermined its credibility.

The adequacy of proving that the crime involved more than three armed men, thus satisfying the elements of “robbery in band”.
Whether the inclusion of aggravating circumstances, such as attacking a moving vehicle, was rightly considered in imposing a harsher penalty, despite questions regarding evidence of recidivism.

Whether the lower court erred in considering Baldera’s alleged previous conviction for theft as a circumstance of recidivism, given the timeline of the prior offense in relation to the crime in question.