G.R. No. 120344 - Paddayuman vs. People

A report was submitted by the barrio captain of Lomboy, La Paz, Tarlac, Inocencio Catalan, indicating the presence of an armed stranger in the area on the evening of November 29, 1967.
Catalan’s report, relayed to PC Sgt. Buenaventura Baldoz, led to the deployment of a constabulary detachment to the reported location.
Upon arrival, Catalan confirmed seeing a man sitting by a pile of palay holding a Browning automatic rifle, who introduced himself as associated with Huk Commanders Zaragoza and Torongco.

As the constabulary tried to apprehend the suspect, the encounter escalated when the accused, later identified as Maximo Baltazar y Bondoc, pushed Catalan forward.
In response to the sudden movement and perceived threat, Sgt. Baldoz opened fire against the accused, resulting in injuries including a gunshot wound to the right shoulder and abdominal area.
A constabulary soldier subsequently seized the Browning automatic rifle along with its accessories (magazine pouch containing 38 live rounds).

During custody, the accused admitted to having just joined the group headed by Huk Commanders Zaragoza and Torongco.
An extrajudicial confession was executed before Municipal Judge Primitivo Adaoag, which was later marked as Exhibit A in the evidence record.

During trial, the prosecution established the commission of overt acts in compliance with the two-witness rule, supported notably by the testimonies of Catalan and Baldoz.
The defense, led by counsel de oficio, argued that the presumption of innocence was not overcome, the two-witness rule was not properly satisfied, and that the extrajudicial confession should have been excluded.
Despite a detailed and exhaustive brief by defense counsel, the trial court’s factual findings were accorded great weight in its determination.

The trial court found the guilt of the accused under the Anti-Subversion Act, imposing reclusion perpetua based on the evidence and his actions.
On appellate review, while the conviction was confirmed, it was determined that the facts presented a mitigating circumstance because of the accused’s lack of instruction and the socio-political context of agrarian unrest.
Consequently, the severe penalty was moderated by reducing the sentence to reclusion temporal, with further relief granted by immediate release due to the time already served.

Whether the trial court erred in concluding that the evidence—especially the two eyewitness testimonies—adequately satisfied the two-witness rule in establishing the commission of overt acts.
Whether the clear and concerted attempt of the accused to disguise his affiliation with subversive activities was properly demonstrated through the evidence.

Whether the extrajudicial confession executed before the Municipal Judge should have been excluded on grounds related to the constitutional prohibition against compelled self-incrimination.
Whether the confession, being part of the witness testimony rather than the sole basis of conviction, retained its evidentiary value.

Whether the defense’s contention that the presumption of innocence was not overcome by the state’s evidence holds merit.
Whether the cumulative evidence, including the factual nuances observed by the trial court, justifies the conviction beyond mere suspicion.

Whether the mitigating circumstance—specifically the accused’s lack of instruction and socio-economic background—warrants a reduction in the severity of the penalty despite the established guilt.
Whether alternative circumstances pointed out in the Revised Penal Code have been appropriately balanced against the gravity of the subversive act.