Case Summary (G.R. No. 128106-07)
Evidence and Antecedent Facts
• Family context: Julio Camacho Sr., security guard; wife Heather; four children. Baldogo and Bermas served as domestic helpers.
• Murder scene: On February 22, 1996, Julie discovered Jorge bloodied in the kitchen, with Baldogo and Bermas each armed with bolos.
• Flight and detention: Baldogo tied and gagged Julie, then dragged her toward the mountains. They recovered buried clothes and provisions, spent nights in forest, and kept Julie under duress.
• Escape and recovery: After six days Baldogo abandoned Julie; she found help and was handed to authorities. Jorge was pronounced dead hours after assault; autopsy confirmed multiple stab wounds and lacerated neck.
• Motive: Both accused harbored resentment over alleged maltreatment by Julio Sr.
Defense Claims
• Baldogo denied participation, asserting he acted under duress from Bermas, who threatened him with death.
• He maintained he protected Julie and had no intention to harm her or Jorge.
• He alleged Julie was coached into implicating him.
Trial Court Findings
• Baldogo found guilty beyond reasonable doubt as co-principal in both offenses.
• Murder (Criminal Case No. 12900): death penalty imposed; aggravating circumstances of evident premeditation and superior strength; damages awarded.
• Kidnapping (Criminal Case No. 12903): reclusion perpetua; damages for Julie’s suffering; Bermas’s case dismissed due to death.
Issues on Appeal
- Sufficiency of proof for murder and kidnapping.
- Credibility of Julie’s testimony versus Baldogo’s denial and claim of coercion.
- Proof of aggravating circumstances (evident premeditation, superior strength, recidivism).
- Propriety of death penalty imposition for murder.
Supreme Court Findings
• Credibility and conspiracy
– RTC’s assessment of Julie’s testimony accorded great respect; no exceptional inconsistencies shown.
– Conspiracy established by joint acts before, during, and after crimes; Baldogo’s active participation rendered him co-principal.
• Duress defense rejected
– Duress must be proven by clear and convincing evidence of imminent peril with no escape; Baldogo failed this burden.
• Aggravating circumstances
– Evident premeditation not established: no clear proof of planning interval or overt preparatory acts.
– Abuse of superior strength absorbed by treachery (victim’s tender age and unarmed state).
– Quasi-recidivism unproven: secondary evidence of prior homicide conviction insufficient under Rules of Court.
• Proper characterization of crimes
– Murder qualified by treachery; penalty range is reclusion perpetua to death; absence of valid aggravating circumstances mandates the penalty of reclusion perpetua.
– Kidnapping and serious illegal detention: dwelling aggravating circumstance not alleged in the information; penalty is
Case Syllabus (G.R. No. 128106-07)
Factual Background
- Julio Camacho Sr., a security guard at Iwahig Prison and Penal Colony, lived with his wife and four children inside the sub-colony: Julio Jr. (college student), Jorge (14), Julie (12), and Jasper (8).
- Two inmates, Edgardo Bermas (alias “Bunso”) and Gonzalo Baldogo (alias “Baguio”), were assigned as domestic helpers to the Camacho household and lived nearby.
- On the evening of February 22, 1996, after serving dinner and while Julio Sr. was at Bible study, Julie heard a scream from the kitchen and found Jorge sprawled and bleeding. Baldogo and Bermas, each armed with a bolo, stood over him.
- Julie fled; the two assailants chased her, tied and gagged her, then dragged her off toward the mountains. They brought provisions, stayed overnight, and detained her for several days before abandoning her on February 28, 1996.
- Julie escaped by following a river, found help with a local resident, and was handed over to authorities. Jorge was brought to the Iwahig Hospital and pronounced dead on arrival; autopsy revealed multiple stab wounds and a fatal neck laceration.
Procedural Posture and Indictments
- Two separate Informations charged Baldogo (and Bermas) with:
• Murder of Jorge Camacho, alleging treachery, evident premeditation, and recidivism (Art. 248, RPC as amended by R.A. 7659).
• Kidnapping and serious illegal detention of Julie Camacho, alleging recidivism (Art. 267, RPC as amended). - Both accused pleaded not guilty on June 28, 1996. Bermas died before arraignment; the cases were consolidated for joint trial.
- The prosecution presented four witnesses (Julie Camacho, Dr. Edilberto Joaquin, Esteban Mamites, Julio Camacho Sr.) and documentary evidence. Baldogo testified in his own defense.
Trial Court Findings and Sentence
- On October 18, 1996, the Regional Trial Court (Branch 52, Puerto Princesa) found Baldogo guilty beyond reasonable doubt as principal in both crimes.
- Murder (Crim. Case No. 12900): Qualified by evident premed