Case Summary (G.R. No. 134564)
Facts of the Case
On October 21, 1997, an information was filed charging Jose Balleras with murder under Article 248 of the Revised Penal Code. The charge stemmed from an incident that occurred on May 18, 1997, wherein Balleras, armed with an unlicensed firearm, shot Rufino Tambo multiple times during a drinking spree outside Tambo’s residence. Rufino died instantly, and his daughter Rosie sustained a gunshot wound.
Prosecution's Evidence
During the trial, the prosecution presented eyewitness testimony from Anita and Rosie Tambo, who positively identified Jose Balleras as the shooter. They recounted that Balleras approached the group and shot Rufino three times. The scene was illuminated by moonlight and an oil burner, allowing for clear visibility. An Autopsy Report corroborated the cause of death as multiple gunshot wounds.
Defense's Argument
In his defense, Jose Balleras denied the allegations, claiming he had an alibi and was at home with his wife and friends at the time of the incident. His assertion was supported by the negative results of a paraffin test conducted after his arrest. His defense witnesses corroborated his alibi, stating he was home during the timeframe of the shooting.
Trial Court Decision
On June 8, 1998, the RTC convicted Balleras of murder, sentencing him to death and ordering him to pay the heirs of Rufino Tambo for damages. The decision emphasized the positive identification by eyewitnesses. Balleras raised several issues on appeal, asserting errors by the trial court regarding the conviction and the damages awarded.
Assessment of Eyewitness Credibility
The appellate court upheld the trial court's credibility assessments of the prosecution witnesses, reinforcing that eyewitness accounts in criminal cases are often regarded highly, particularly when the witnesses have an established familiarity with both the victim and the accused.
Evidence Evaluation
The appellate court noted that the absence of positive nitrates in the paraffin test does not conclusively absolve an individual from guilt. It emphasized that the defense of alibi is typically weak and does not sufficiently counter the compelling identification by eyewitnesses, especially in light of the proximity of Balleras' residence to the scene of the crime.
Classification of the Crime
The trial court categorized the crime as murder, qualifying it under the presence of treachery, as Balleras attacked Rufino without any warning. Though the trial court initially considered evident premeditation as an aggravating circumstance, the appellate court determined that the requisite elements of premeditation were not sufficiently proven in this case.
Aggravating Circumstances and Sentencing
The appellate court concluded that, while treachery qualified the crime as murder, no aggravating
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Case Overview
- This case involves an automatic review of the Decision dated June 8, 1998, from the Regional Trial Court (RTC), Branch 46, Urdaneta, Pangasinan.
- The accused, Jose Balleras, was found guilty of murder and sentenced to death, alongside an order to indemnify the victim’s heirs.
- The crime occurred on May 18, 1997, in Barangay San Bonifacio, San Manuel, Pangasinan.
Charges Against the Accused
- The information filed against Balleras described the murder committed with treachery and evident premeditation using an unlicensed firearm.
- The specific allegation was that Balleras shot Rufino Tambo multiple times, resulting in Tambo's instantaneous death.
Factual Background
- On the night of the incident, Rufino Tambo, his daughter Rosie, and others were drinking in front of their home.
- An unidentified assailant emerged from an irrigation canal, shot Tambo, and threatened witnesses.
- Rosie Tambo was injured in the attack while witnesses fled.
Prosecution's Evidence
- The prosecution presented eyewitness accounts from Anita and Rosie Tambo, who recognized Balleras as the shooter.
- The autopsy report confirmed Tambo's death was due to multiple gunshot wounds.
- Witness testimonies described the assailant's actions and the context of the crime, including a familial connection between the victim and the accused.
Defense of the Accused
- Balleras denied the charges, asserting he was at home during the time of the murder.
- He provided alibi testimony corroborated by o