G.R. No. 134564 - People vs. Balleras

On May 18, 1997, in the evening at Barangay San Bonifacio, San Manuel, Pangasinan, a drinking session was in progress at the residence of Rufino Tambo.
Among those present were Rufino Tambo, his 12-year-old daughter Rosie Tambo, his common-law wife Anita Tambo, and other individuals including Ruben Collado and Ruben Cabreros.
The area was illuminated by moonlight and an improvised oil burner, providing sufficient light for the events to unfold.

A man, later identified as Jose Balleras, emerged from an irrigation canal with his face covered by a white bonnet and armed with a long, unlicensed firearm.
Without warning, he approached the group and shot Rufino Tambo three times, resulting in the victim’s instantaneous death.
During the attack, the assailant threatened, "If you will not get out of here, I will kill you all," and then fled the scene.
Rosie Tambo, despite suffering a gunshot wound on her left spinal column, and Anita Tambo, who had witnessed the events from inside the house, managed to identify the accused when he removed his white bonnet.

Eyewitnesses Anita and Rosie Tambo provided consistent and detailed identifications of the accused, linking him directly to the shooting.
The autopsy report, prepared by Dr. Asuncion C. Tuvera on May 19, 1997, confirmed that Rufino Tambo died from massive hemorrhage due to multiple gunshot wounds at specific entry points.
Other testimonies, including those of Domingo Abalos (who assisted in bringing Rosie to the hospital) and corroborating witnesses such as Elpidio and Marcela Pote, strengthened the prosecution’s case.

Jose Balleras, upon arraignment, pleaded not guilty and provided an alibi, stating that from 7:30 p.m. up to 10:00 p.m. on the day of the crime, he was at home with his wife Adelina Balleras and acquaintances, Elpidio and Marcela Pote.
A paraffin test conducted on the accused yielded negative results, which he argued supported his alibi; however, this evidence was later deemed inconclusive by the courts due to the known limitations of such tests.

The Regional Trial Court (RTC), Branch 46, Urdaneta, Pangasinan, in Criminal Case No. U-9381, rendered its decision on June 8, 1998, convicting Jose Balleras of murder based on the established facts and testimonies.
The court sentenced him to the death penalty and ordered him to indemnify the heirs of Rufino Tambo with P20,000.00 for actual expenses and P50,000.00 as damages (later designated as civil indemnity).
The accused raised assignments of error on appeal, contesting both his conviction for murder and the award of indemnity.

Whether the trial court erred in giving significant weight to the testimonies of Anita and Rosie Tambo, who identified the accused.
Whether the conditions of the scene (moonlit night and sufficient illumination by an oil burner) provided an environment adequate for proper identification.

Whether the negative paraffin test result could conclusively negate the possibility that the accused discharged his firearm during the crime.
The relevance of forensic limitations in assessing the physical evidence against the accused.

Whether the accused’s claim of being at home during the time of the crime, a location only two kilometers away from the incident, was sufficiently proven to warrant the acceptance of an alibi.
Whether the physical proximity of his residence to the crime scene undermines the credibility of his alibi.

Whether the trial court correctly qualified the crime as murder by virtue of treachery.
Whether the trial court mistakenly imposed the element of evident premeditation as an aggravating circumstance despite insufficient evidence for the same.

Whether the tribunal properly ordered the payment of P20,000.00 for actual expenses and P50,000.00 as damages (civil indemnity) to the heirs of the victim.