G.R. No. L-30573 - Domingo vs. Domingo

This is a criminal case involving the People of the Philippines versus Edmundo de Guzman (also known as Jojo) as the principal accused in a murder case.
The trial court, Regional Trial Court, Branch XIX of Bacoor, Cavite, rendered a decision in Criminal Case No. B-85-87 charging accused de Guzman with murder (qualified with treachery and with the aggravating circumstance of dwelling) while dismissing the cases against Perfecto Gueta and Joel Gueta for lack of evidence on conspiracy.

On the evening of January 29, 1985, Luis Baliber, Sr. was fatally shot while watching a television program at his residence.
According to the prosecution’s account, the assailant entered the victim’s house and directed a series of orders—coercing an individual (Joaquin Carique) to enter the premises—before firing successive shots that struck the victim.
Eyewitnesses provided descriptions and accounts of the incident, noting that the shooter was seen carrying a long gun, wearing a jacket, and later identified by distinct physical attributes during his approach to the victim’s house.

The appellant (Edmundo de Guzman) claimed that on the night in question he was at home drinking beer with a neighbor, Rodolfo Saique, asserting that he never left his residence. He further explained his presence at other locations due to family concerns including the childbirth of his wife and his child’s illness.
The defense introduced an alibi asserting that the accused could not have been present at the scene given his activities that evening, and attempted to point to eyewitness descriptions that did not match his physical appearance (e.g., the alleged killer was described as taller and having a big stomach, in contrast to de Guzman’s presentation).
However, the prosecution countered with a series of eyewitness accounts from individuals such as Joaquin Carique, Mrs. Francia Baliber, and Luis Baliber, Jr., all of whom described in detail the movements and appearance of the assailant, linking him directly to the act.

During the trial, the presiding judge conducted a comprehensive examination by asking detailed, clarificatory questions to both prosecution and defense witnesses, including a significant cross-examination of the accused.
The judge’s inquiries delved into the accused’s whereabouts, his relationship with the victim, his actions on the day of the incident, and the credibility of the alibi put forward.
The accused’s responses, including those related to the timing and purpose of his movements, were aimed at countering the direct identification by the witnesses, though they left certain ambiguities.

Forensic examinations revealed that the victim suffered from multiple gunshot wounds (fifteen in number), with many of the shots entering at the back and head, corroborating the element of treachery as claimed by the prosecution.
Documentary evidence, including autopsy reports and established timelines, substantiated the sequence of events depicted by the eyewitness testimonies.

After visiting co-accused Perfecto Gueta and Joel Gueta during their detention, the accused was in turn arrested, despite protests of innocence.
The trial record reflects that issues pertaining to the credibility of witness testimonies and the rigorous cross-examination were central to establishing the facts in the case.

Whether the trial court, through its conduct in questioning witnesses (including cross-examining the defense witnesses), treated the accused in a manner that violated his right to due process by exhibiting bias in favor of the prosecution.

Whether the prosecution failed to meet its burden of proving the guilt of the accused beyond reasonable doubt based on the evidentiary record, including eyewitness identifications, testimonial inconsistencies, and the defense’s claim of alibi.
The accused argued that the contradictory nature of the prosecution’s evidence, along with the presentation of an alibi, should have led to an acquittal.