Case Summary (G.R. No. 73464)
Facts of the Case
Luis Baliber, Sr. was killed by gunshot wounds while watching television at his home on January 29, 1985. The prosecution claims that Edmundo de Guzman was the assailant, while the defense presents an alibi stating that de Guzman was at home with a neighbor during the time of the incident. The trial court acquitted co-accused Perfecto and Joel Gueta due to insufficient evidence of conspiracy.
Trial Court Decision
The Regional Trial Court found Edmundo de Guzman guilty of murder with treachery, given the nature of the attack. The court determined that the murder was committed with the aggravating circumstance of dwelling. Thus, de Guzman was sentenced to death and ordered to pay indemnities to the victim's heirs.
Appellant's Claims of Error
The appellant raised two primary errors: firstly, that he was denied due process due to alleged bias from the presiding judge, who engaged in cross-examining defense witnesses; and secondly, that the prosecution failed to establish his guilt beyond a reasonable doubt. He argued that the evidence was contradictory and that the defense had presented credible evidence of his innocence.
Court’s Findings on the Errors
The court refuted the claim of judicial bias by stating that the presiding judge's inquiries were aimed at clarifying witness testimonies rather than discrediting them. The judge's probing questions were regarded as necessary to discern the truth and did not infringe on the appellant's rights. Regarding the claim of insufficient evidence, the court emphasized the credible testimonies of eyewitnesses which convincingly identified de Guzman as the shooter.
Defense of Alibi
The defense contended that de Guzman had an alibi, asserting that he was at home during the shooting. However, the proximity of his residence to the crime scene undermined this defense, as it did not eliminate the possibility of his presence at the location of the murder. The court concluded that the positive identification of de Guzman by multiple witnesses outweighed his alibi claim.
Elements of Murder and Treachery
The court established that the crime was committed with treachery, highlighting that the victim was killed while defensively unprepared. The assailant approached the victim during a moment of vulnerability, en
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Case Overview
- The case involves the People of the Philippines as the plaintiff against Edmundo de Guzman (also known as Jojo), Perfecto Gueta, and Joel Gueta, the accused in a murder case.
- The decision to be reviewed originates from the Regional Trial Court, Branch XIX in Bacoor, Cavite, in Criminal Case No. B-85-87.
- The key issue is the murder of Luis Baliber, Sr., who was shot and killed in his home on January 29, 1985.
Disposition by the Regional Trial Court
- Edmundo de Guzman was found guilty beyond reasonable doubt of murder qualified by treachery.
- The court sentenced him to death, along with financial penalties: P30,000.00 for indemnity, P10,000.00 in moral damages, and P5,000.00 in exemplary damages.
- The cases against Perfecto Gueta and Joel Gueta were dismissed due to lack of evidence proving their involvement in a conspiracy to commit murder.
Incident Background
- Luis Baliber, Sr. was shot and killed while watching television at home.
- Evidence indicated that the assailant entered the room and shot him.
- The prosecution alleged that Edmundo de Guzman was the shooter, while the defense presented an alibi.
Prosecution's Statement of Facts
- Eyewitnesses, including Joaquin Carique and Francia Baliber, provided testimonies that placed Edmundo de Guzman at the scene of the crime.
- Carique observed de Guzman peeping into the Baliber store and later saw him carrying a gun.
- Francia Baliber witnessed de Guzman shoot her husband, leading to the victim suffering multiple gunshot wounds (14 in total).
- The