Title
People vs Baua
Case
G.R. No. 8971
Decision Date
Mar 14, 1914
A 12-year-old boy was found dead with 44 wounds; a young witness accused Cirilo Baua, but inconsistencies and lack of corroboration led to his acquittal.

Case Summary (G.R. No. 8971)

Background of the Case

Cirilo Baua was convicted of murder by the Court of First Instance of Cagayan and sentenced to imprisonment for seventeen years, four months, and one day, alongside indemnification for the heirs of the deceased, Jose Garma. The case arose from a brutal homicide involving Garma, who was discovered dead with forty-four wounds on his body two days after he went missing. The core of the prosecution's argument relied heavily on the testimony of a singular eyewitness, Gaspar Paguirigan, a boy aged 12-15 years.

Testimony of Eyewitness

Gaspar Paguirigan testified that he accompanied Cirilo Baua, who allegedly harbored malicious intent towards Garma. According to Gaspar, Baua attacked Garma, who pleaded for mercy. Gaspar's narrative presented numerous details about the attack and conveyed a threat made by Baua to silence him. However, it was noted that Gaspar had a prior dispute with Garma, which painted him as a potentially unreliable witness due to established hostility between them.

Weakness in Prosecution's Case

The prosecution's case suffered from a lack of corroborative testimonies, other than Gaspar's. The mother of the deceased could only provide hearsay regarding the events, emphasizing that her son had an antagonistic relationship with Gaspar. Other witnesses failed to corroborate Gaspar's allegation that Baua was responsible for the murder, reinforcing the idea that the case hinged significantly on the credibility of one individual's testimony.

Defense Testimony and Evidence

The defense brought witnesses who testified that Baua was located elsewhere during the time of the murder. Notably, forensic testimony indicated that the wounds on Gaspar’s shoulder and thumb were inflicted by a "cutting instrument", raising questions about Gaspar’s own involvement. Furthermore, another witness, Aurelia Marfil, recounted an incident where Gaspar allegedly attempted to hide the bolo, which was directly linked to the crime.

Evaluation of Gaspar's Credibility

The appellate court scrutinized Gaspar’s testimony due to evident contradictions, specifically regarding his accounts of prior incidents with Garma and the circumstances leading to his injuries. His insistence on certain details, such as the origin of stains on his clothing and the nature of his injuries, appeared suspicious and served to undermine his credibility. The relationship dynamics and animosity between Gaspar and Garma further suggested potential motive for deception.

Jury Judgment and Reasoning

The trial court initially convicted Baua based on what it deemed credible testimony from Gaspar. However, upon review, th

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