GR 129933; (February, 2001) (Digest)
G.R. No. 129933 February 26, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FEDERICO BALTAZAR y PIMENTEL alias “TODONG”, accused-appellant.
FACTS
The prosecution established that on the evening of November 16, 1994, in Cuartero, Capiz, accused-appellant Federico Baltazar and an unidentified companion went to the house of Reynaldo Gardose. Perla Gardose, the victim’s wife, opened the door, recognized Baltazar, and heard him ask her husband to accompany them. Reynaldo obliged and walked with the two men along a feeder road. Eyewitness Rodney Hallegado, who was waiting nearby, saw Baltazar draw a firearm and shoot Reynaldo from behind as the victim was about to turn. Reynaldo died from a gunshot wound. The following morning, Perla discovered her husband’s body and reported the crime.
The defense interposed denial and alibi. Baltazar claimed he was at home with his wife the entire evening. A forensic chemist also testified that a paraffin test conducted on Baltazar’s hands days after the incident yielded a negative result for gunpowder nitrates. The Regional Trial Court convicted Baltazar of Murder qualified by treachery and sentenced him to reclusion perpetua, ordering him to pay damages to the victim’s heirs.
ISSUE
Whether the trial court erred in convicting the accused-appellant of Murder based on the testimonies of the prosecution witnesses and in disregarding the negative paraffin test result.
RULING
The Supreme Court affirmed the conviction. The positive and categorical identification of the accused-appellant by eyewitness Rodney Hallegado, who had no ill motive to testify falsely, prevails over his denial and alibi. The Court found Hallegado’s testimony credible, detailed, and consistent with the natural course of events. It was corroborated by Perla Gardose, who placed Baltazar at the scene immediately before the shooting. The alleged discrepancies between their testimonies were minor and did not affect the core narrative of the crime.
Regarding the negative paraffin test, the Court ruled it is not conclusive proof of innocence. The test, conducted several days after the incident, has limited reliability; gunpowder residues can be removed by washing or may not be deposited if a weapon is properly held. The positive testimony of a credible eyewitness carries more weight. The qualifying circumstance of treachery was correctly appreciated as the attack was sudden and from behind, ensuring the victim had no opportunity to defend himself. The penalty of reclusion perpetua was affirmed, but the awarded damages were modified, increasing the indemnity for loss of earning capacity.