GR 30557; (March, 1980) (Digest)
G.R. No. L-30557, March 28, 1980
The People of the Philippines, plaintiff-appellee, vs. Maximo Baltazar y Bondoc, accused-appellant.
FACTS
Accused-appellant Maximo Baltazar was convicted of violating the Anti-Subversion Act (Republic Act No. 1700) and sentenced to reclusion perpetua. The prosecution stemmed from his apprehension on November 29, 1967, in Barrio Lomboy, La Paz, Tarlac. Acting on a report from Barrio Captain Inocencio Catalan about an armed stranger, PC Sgt. Buenaventura Baldoz set up an operation. Catalan made contact with Baltazar, who was carrying a Browning automatic rifle and identified himself as a man of Huk Commander Zaragoza. As Catalan led him towards an ambush point, Baltazar suddenly pushed Catalan forward, prompting Sgt. Baldoz to open fire, wounding Baltazar. Upon arrest, Baltazar admitted to having recently joined Huk commanders and later executed an extrajudicial confession before a municipal judge.
ISSUE
The core issues for resolution were: (1) whether the prosecution evidence overcame the constitutional presumption of innocence; (2) whether the two-witness rule for subversion was satisfied; and (3) whether the extrajudicial confession was admissible and properly considered.
RULING
The Supreme Court affirmed the conviction but modified the penalty. The Court held that the trial court’s factual findings, including the credibility of witnesses Catalan and Baldoz, were entitled to great weight and respect on appeal. Their testimonies sufficiently established Baltazar’s membership in the subversive organization and his possession of a firearm in furtherance thereof, thereby complying with the two-witness rule required under the Anti-Subversion Act. The Court further ruled that the extrajudicial confession, while not the sole basis for conviction, was admissible. The conviction was primarily anchored on the independent and corroborative testimonies of the prosecution witnesses regarding his capture and admissions, not merely on the confession itself.
However, the Court found a mitigating circumstance in Baltazar’s favor—that of voluntary surrender or an analogous circumstance. The record indicated he surrendered to authorities through Barrio Captain Catalan after being located, which was not contradicted by the prosecution. Applying this mitigating circumstance under the Revised Penal Code, the penalty was reduced from reclusion perpetua to an indeterminate penalty of six years of prision correccional minimum to eight years and one day of prision mayor maximum. As Baltazar had already been imprisoned for a period exceeding this new penalty, the Court ordered his immediate release. The decision was immediately executory.