G.R. No. L-31568 - People vs. Dorico

On November 16, 1994, at around 10:00 p.m., in sitio Hanalon, Brgy. Malagab-i, Cuartero, Capiz, the accused, Federico Baltazar y Pimentel (alias "Todong"), allegedly used a firearm to shoot Reynaldo Gardose.
The shooting was committed with treachery—an element characterized by methods that leave the victim no chance to defend himself.
The Information described the crime as one committed with intent to kill using means and manner that insured execution without risk to the offender.

At around 9:30 p.m., Rodney Hallegado accompanied Reynaldo Gardose to a ricefield.
After a brief stop for a drink at Rodney’s house, a call for Reynaldo prompted him to leave his wife’s presence.
Rodney observed the accused, along with another unidentified man, arriving at Reynaldo’s residence.
He testified that he saw the accused walk with Reynaldo, and then suddenly drew a firearm and shot the victim as Reynaldo was about to turn right.
Fearing for his safety after hearing the shot, Rodney hid and later reported the incident.

Perla answered a call at the door and identified the accused from a distance as a known resident.
She observed her husband when he went downstairs accompanied by the accused and the unidentified man.
After a brief lapse (attending to her newborn), she heard a gunshot.
The following morning, while out on the feeder road, she discovered Reynaldo’s lifeless body and promptly reported the incident to the authorities.

Captain Angela Baldevieso, a forensic chemist, conducted a paraffin test on a cast taken from the accused’s hands on November 21, 1994.
The test yielded a negative result for gunpowder nitrates.
This negative result, however, was later qualified as inconclusive due to possible external factors that could affect such tests.

The accused, together with his wife Luzviminda Baltazar, claimed they were together in the ricefield earlier that day and had supper at 6:00 p.m.
He stated that he remained in the house until the following morning when police and a CAFGU member visited for questioning.

The accused argued that the negative paraffin test supports his denial of firing a weapon as no gunpowder residue was detected.

The Regional Trial Court of Roxas City, Branch 16, found the accused guilty beyond reasonable doubt for the crime of murder.
In rendering its decision on January 28, 1997, the trial court sentenced the accused to reclusion perpetua with the caveat that the penalty was fixed for 25 years (in contrast to the indivisible nature of reclusion perpetua).
The decision also included a civil liability award with detailed computation for lost earnings, actual damages, moral damages, and death indemnity—with some modifications required on appeal.

Alleging improper assessment and undue credence given to eyewitness testimony, particularly that of Rodney Hallegado.
Accusing the trial court of ignoring material discrepancies between the testimonies of Hallegado and Perla Gardose.
Challenging the evaluation of the negative paraffin test as an aid to establish his innocence.
Asserting that the witness’s alleged ulterior motive (related to agrarian disputes) should have nullified his positive identification of the accused.

Whether the trial court committed reversible error by placing full credence on Rodney Hallegado’s testimony without properly considering alleged improper motives.
Whether minor inconsistencies between Hallegado’s and Perla Gardose’s testimonies undermine their overall credibility.

Whether the negative result of the paraffin test should have been given greater significance as evidence of the accused’s alibi.
Whether external factors that could influence the paraffin test were adequately considered by the trial court.

Whether the accused’s claim of being in the ricefield and at home at the time of the crime is sufficiently supported by positive, clear, and satisfactory proof.
The legal threshold for an alibi to prevail against eyewitness identification.

Whether the trial court correctly applied the element of treachery in qualifying the crime as murder.
Whether the determination of reclusion perpetua as an indivisible penalty was adequately respected, notwithstanding the trial court’s reference to a fixed duration of 25 years.