Case Digest (G.R. No. 120921)
Facts:
The People of the Philippines v. Felipe Ballesteros, Cesar Galo and Alvin Bulusan, G.R. No. 120921, January 29, 1998, the Supreme Court Third Division, Romero, J., writing for the Court.The criminal information arose from a late evening shooting on May 28, 1991, near a barangay hall in Ganayao, Pasuquin, Ilocos Norte. A group that had attended a dance — including Carmelo Agliam, Eduardo Tolentino, Sr., Vidal Agliam, Jerry Agliam, Robert Cacal, Ronnel Tolentino and others — left the dance because of perceived hostility from Cesar Galo and companions. Shortly thereafter, their owner jeep was fired upon from the rear; Jerry Agliam and Eduardo Tolentino, Sr. were killed, and four others were wounded.
Based on affidavits of Carmelo and Vidal Agliam, warrants were issued and an information charging double murder with multiple frustrated murder was filed against accused-appellants Felipe Ballesteros, Cesar Galo and Alvin Bulusan. The prosecution presented eyewitness testimony identifying the accused at the scene, and paraffin (gunpowder residue) tests on Galo and Ballesteros yielded positive results; Bulusan was not tested. Each accused pleaded not guilty and interposed defenses: Galo denied presence and attributed paraffin residue to cigarette smoking; Ballesteros raised alibi and blamed fertilizer and cigarette handling for nitrates; Bulusan also pleaded alibi, claiming he slept at a neighbor’s house.
The Regional Trial Court, Branch 19, Bangui, Ilocos Norte, found the three accused guilty beyond reasonable doubt of murder qualified by treachery under Article 248 of the Revised Penal Code and sentenced them to reclusion perpetua with accessory penalties, ordering various awards of actual, compensatory/indemnity and moral damages to the victi...(Pro-only)
Issues:
- Was the conviction for murder (qualified by treachery) correct, considering the eyewitness identifications and physical evidence?
- Were the paraffin test results and the accused-appellants’ alibi defenses sufficiently persuasive to negate guilt?
- Was the qualification of the crime by treachery properly found?
- Were the awards of actual, compensatory/indemnity and moral damages pro...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)