Case Digest (G.R. No. 128106-07)
Facts:
People of the Philippines v. Gonzalo Baldogo, G.R. Nos. 128106-07, January 24, 2003, Supreme Court En Banc, Callejo, Sr., J., writing for the Court. The case is an automatic review of the Joint Judgment of the Regional Trial Court, Branch 52, Puerto Princesa City (penalized on October 18, 1996, penned by Judge Felomino A. Vergara), which convicted Gonzalo Baldogo (accused-appellant) of murder in Criminal Case No. 12900 and kidnapping with serious illegal detention in Criminal Case No. 12903, sentencing him to death and reclusion perpetua, respectively.The informations charged Baldogo and co-accused Edgardo Bermas with conspiring to kill 14-year-old Jorge Camacho and kidnapping/detaining 12-year-old Julie Camacho on February 22, 1996 at the Iwahig Prison and Penal Farm, Puerto Princesa City. Bermas died before arraignment; the cases were consolidated and Baldogo pleaded not guilty. The prosecution presented four witnesses (Julie Camacho, Dr. Edilberto Joaquin, Esteban Mamites and Julio Camacho, Sr.) and documentary/object evidence including a medical certificate (autopsy) and prison records.
The narrated facts from trial evidence show that, on the evening of February 22, 1996, Julie discovered Jorge sprawled and bloodied in the kitchen with Baldogo and Bermas standing over him armed with bolos; Julie fled but Baldogo overtook, gagged and bound her, and dragged her toward the mountains. Baldogo and Bermas retrieved a buried bag of clothes and provisions, trekked into the mountains, and detained Julie for several days; eventually Baldogo left her, after which Julie returned to the lowlands and was recovered by authorities. Jorge was brought to the Iwahig Hospital and pronounced dead; the autopsy established multiple stab wounds and neck laceration causing fatal hemorrhage. The prosecution also introduced an excerpt of Baldogo’s prison file showing an earlier homicide conviction and that he was serving sentence at the time.
At trial Baldogo denied participation, claimed duress and that Bermas acted alone, and testified he was maltreated by Julio Sr. He admitted various movements (e.g., that he left Julie and later fled and was arrested). The trial court found Baldogo guilty as principal of murder and of kidnapping/serious illegal detention and imposed the death penalty for murder and reclusion perpetua for kidnapping, ordering civil and moral damages; the ca...(Subscriber-Only)
Issues:
- Did the trial court err in finding Gonzalo Baldogo guilty beyond reasonable doubt of murder and kidnapping with serious illegal detention?
- Did the trial court err in rejecting Baldogo’s defenses of denial and duress?
- Did the trial court err in appreciating the qualifying aggravating circumstance of evident premeditation and the generic aggravating circumstance of abuse of superior strength?
- Did the trial court err in imposing the death pen...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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