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PEOPLE v. FELIPE BALLESTEROS

FACTS:

In the warm summer evening of May 28, 1991, Carmelo Agliam, his half-brother Eduardo Tolentino, Ronnel Tolentino, Vidal Agliam, his brother Jerry Agliam, Robert Cacal, Raymundo Bangi, and Marcial Barid gathered at a carinderia owned by Ronnel Tolentino at Ganayao, Pasuquin, Ilocos Norte. They decided to attend a dance at the barangay hall in Carusipan. However, they sensed hostility from Cesar Galo and his companions, who were giving them dagger looks. To avoid trouble, they decided to go home instead of reacting to the perceived provocation.

As the group was leaving, within fifty meters from the dance hall, their owner jeep was fired upon from the rear. Vidal Agliam jumped out and hid in the ricefield, while Jerry Agliam was shot in the stomach and died. Carmelo Agliam, Robert Cacal, and Ronnel Tolentino sustained injuries. Eduardo Tolentino, who was stunned, was hit with a bullet that punctured his right kidney and did not survive.

Based on the affidavits of Carmelo and Vidal Agliam, warrants of arrest were issued for Ballesteros, Galo, and Bulusan. They were charged with double murder with multiple frustrated murder. Paraffin tests conducted on Galo and Ballesteros produced positive results.

During the trial, Galo claimed that he did not talk to Bulusan or any of his companions at the basketball court and tried to discredit the paraffin test results. Ballesteros asserted the defense of alibi, stating that he was not present at the crime scene when the firing incident took place. Bulusan echoed the defense of alibi of Galo and Ballesteros.

The trial court found the three accused guilty beyond reasonable doubt of murder, qualified by treachery, under Article 248 of the Revised Penal Code. The accused appealed to the Supreme Court, seeking reversal of the trial court's decision.

ISSUES:

  1. Were the accused-appellants correctly found guilty beyond reasonable doubt?

  2. Is motive essential in proving the commission of a crime?

  3. Whether the defense of alibi of the accused was credible and supported by credible corroboration from disinterested witnesses.

  4. Whether the offense was qualified by treachery.

  5. Whether the award of damages to the heirs of the victims was proper.

RULING:

  1. The accused-appellants were correctly found guilty beyond reasonable doubt. The court affirmed the decision of the trial court, ruling that the identification of the accused as the assailants by the victims was reliable. The area where the shooting took place was well-illuminated by the moon, and there were no elements to obstruct the vision of the victims. The victims were also familiar with the accused, which further supported their ability to identify them as the perpetrators. The defense's attempt to offer wild excuses for the gunpowder traces found on their hands was deemed futile, as experts confirmed that these traces were consistent with handling firearms.

  2. Motive is not essential in proving the commission of a crime. While motive may help establish intent, it is not a requirement for conviction. The court emphasized that motive alone is not proof of a crime, and it is intent that needs to be established by the prosecution. The lack of motive on the part of the accused does not preclude conviction if there are reliable witnesses who positively identify them as the perpetrators of the felony.

  3. The defense of alibi of the accused was not credible and not supported by credible corroboration from disinterested witnesses. The presentation of corroborative testimony is necessary to reinforce the defense of alibi. Failure to present witnesses who could have testified to having seen them elsewhere during the commission of the offense is fatal to the accused.

  4. The offense was qualified by treachery. The requisites of treachery are: (1) at the time of the attack, the victim was not in a position to defend himself; and (2) the offender consciously adopted the particular means, method, or form of attack employed by him. In this case, the victims were totally unaware of the presence of the accused, who were well-armed and approached the victims from behind. There was no opportunity for the victims to defend themselves.

  5. The award of damages to the heirs of the victims was proper. Actual or compensatory damages are awarded to compensate for loss or injury sustained. In this case, the claim for actual damages by the heirs of the victims was substantiated by receipts presented in court. However, the order granting compensatory damages must be amended, and instead, an indemnity amount of fifty thousand pesos (P50,000.00) is awarded to the heirs of the victims. The amount of moral damages is left to the discretion of the trial court.

PRINCIPLES:

  • The identification of the accused as the assailants by reliable witnesses prevails over alibi, denials, and excuses.

  • Proof beyond reasonable doubt does not require absolute certainty, but rather moral certainty.

  • Motive is not an essential element of a crime. Intent, not motive, must be established by the prosecution.

  • An alibi must be supported by credible corroboration from disinterested witnesses. Failure to present witnesses who could have testified to having seen the accused elsewhere during the commission of the offense is fatal to the accused. (People v. Ligotan)

  • Treachery exists when the offender consciously adopted the particular means, method, or form of attack that insured the execution of the crime without risk to himself arising from the defense that the victim might make. The requisites of treachery are: (1) the victim was not in a position to defend himself, and (2) the offender made some preparation to kill his victim in such a manner as to make it impossible or hard for the person attacked to defend himself or retaliate. (Paragraph 16, Article 14 of the Revised Penal Code)

  • Damages may be awarded as pecuniary compensation for an injury sustained. Actual or compensatory damages are awarded for loss or injury sustained, and moral damages may be awarded for mental anguish, serious anxiety, physical suffering, moral shock, and similar experiences directly resulting from the wrongful act or omission of the offender. The best evidence available, such as receipts and vouchers, must be presented to support a claim for actual damages.