G.R. No. L-23405 - People vs. Bato

On April 3, 1959, between 6:30 p.m. and 7:00 p.m., a shooting occurred at the residence of the deceased, Aurelio Laguna, in Barrio Bagahupi, municipality of Babatngon, province of Leyte.
During dinner, while Laguna was seated with his wife, daughter-in-law (Asuncion Canete), and other family members, a gunshot was fired from outside the house.
The bullet struck Laguna in the right paravertebral region at the level of the first and second lumbar vertebrae, perforating vital organs, which resulted in his death the following day.

The seating arrangement was near a half-opened window, allowing witnesses to observe the external activity.
The area was illuminated not only by the light from Laguna’s house but also from a neighbor’s (Florencio Rosales) house and a bonfire across the street in the yard of Ceferino Lacaba.
These light sources played a role in enabling eyewitnesses to clearly identify the individuals involved as they moved near Laguna’s residence immediately after the gunshot.

She heard the report of a gun and looked out of the window (located just over one meter from the ground).
She observed defendant Domingo Bato, along with Justiniano Ballais and Maximo Saldivia, in a squatting position, as if preparing to run.
She noted that Bato was holding a gun, while Ballais and Saldivia had each a bolo.
She reported that, after the shot, Laguna himself identified Bato as his assailant to his wife.

Upon hearing the gunshot, she moved to the kitchen door and saw Bato running away, pistol in hand, followed by Ballais and Saldivia.
She further confirmed that her husband had identified Bato as the one who fired the shot.

Barrio lieutenant Gavino Tenedo and municipal mayor Ricardo Ansale, along with rural policeman Pedro Dosar, confirmed Mrs. Laguna’s account regarding her husband’s identification of Bato.
Vicente Duallo stated that while heading towards Laguna’s house, he heard the gunshot and saw Bato with two other persons running away from an area near Florencio Rosales’ residence.

Domingo Bato claimed that he was with his family in the camarin of Quinto Bato, a residence located approximately 800 meters from Laguna’s house, and did not leave at the time of the incident.
Felicisimo Bacquiano’s testimony ostensibly corroborated this account by asserting his presence with Bato during that evening.

Ballais and Saldivia testified that they were in their respective houses at the time of the occurrence.
Pedro Dosar attempted to validate Saldivia’s version by mentioning his presence at Saldivia’s house when the gun was fired, although he later confirmed the fact of Mrs. Laguna’s account.

Historically, Laguna had reported to the Constabulary that Bato was known to carry a firearm for threatening him.
Bato had a prior charge for illegal possession of firearms, though the case was dismissed.
A report had been submitted by Laguna to the provincial health officer regarding the indiscriminate slaughter of dying carabaos by Bato a week or two before the incident.
Laguna had also been involved as either a plaintiff or a witness in several land disputes concerning Quinto Bato, an uncle of the defendant.

The central issue in the case is the proper identification of the individual responsible for the fatal shooting of Aurelio Laguna.
Whether the multiple, corroborative eyewitness testimonies that pinpoint Domingo Bato as the firearm user should be given more weight over the defendant’s claim of an alibi.

The reliability of the eyewitness evidence provided by Laguna’s relatives, neighbors, and law enforcement officers versus the defense testimonies and alibi presented by Bato and his co-accused.
The matter of reconciling minor discrepancies in the accounts, particularly regarding the presence and actions of Ballais, Saldivia, and Bato.

How the circumstantial evidence, including Laguna’s earlier interactions with Bato and reports of his threatening behavior, supports the identification of Bato as the assailant.
Whether the evidentiary details surrounding the lighting and proximity of the houses provide a reliable basis for identifying the culprit.