G.R. No. 76585 ; April 30, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODOLFO BAGUIO y Tampos @ “Bebot”, accused-appellant.

FACTS

Alfredo Paulino, a barangay tanod, was fatally stabbed by a group of men, including Rodolfo “Bebot” Baguio, in front of his Quezon City residence on March 31, 1981. The victim’s widow, Lidovina, testified that she witnessed the attack, seeing Baguio stab her husband twice before the assailants fled. While being assisted to the hospital, the wounded Alfredo repeatedly declared, “Kung ako ay bibigyan pa ng Diyos ng pangalawang buhay, hindi maaaring hindi mananagot si Bebot at Frankie.” He died the following day. Baguio was later identified by the widow in a police lineup. The prosecution presented the widow’s eyewitness account, the medico-legal findings, and the investigating officer’s testimony.
The defense interposed alibi, with Baguio claiming he was working as a painter elsewhere at the time of the killing. He also challenged the admissibility of his sworn statement taken by police and denied the victim’s dying declaration could have been uttered given the severity of his wounds. The trial court convicted Baguio of murder qualified by treachery and abuse of superior strength, sentencing him to reclusion perpetua. He appealed, contesting the evidence against him.

ISSUE

The core issues are: (1) whether the victim’s ante-mortem statement qualifies as a dying declaration or as part of the res gestae; (2) whether the sworn statement of the accused was taken in violation of his constitutional rights; and (3) whether the prosecution proved his guilt beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. First, the victim’s statement is admissible as part of the res gestae. It was made spontaneously after a startling occurrence—the brutal stabbing—while he was being taken to the hospital, relating directly to the circumstances of the attack. The seriousness of his 23 stab wounds supports the spontaneity and reliability of the declaration, which implicated Baguio. Second, the sworn statement (Exhibit C) was properly admitted. The investigating officer testified he informed Baguio of his constitutional rights to remain silent and to counsel before taking the statement. Baguio’s denial of signing it for this case, claiming it was for a different robbery-snatching investigation, was deemed a weak and self-serving assertion that failed to overcome this positive testimony.
The Court found the alibi untenable. It could not prevail over the positive and credible eyewitness identification by the victim’s widow, who had no motive to falsely testify. Her testimony was clear, consistent, and corroborated by the dying declaration. The trial court correctly appreciated treachery, as the attack was sudden and rendered the victim defenseless against multiple assailants. However, the Court modified the penalty by deleting the reference to “life imprisonment,” affirming only reclusion perpetua, and increased the civil indemnity to P50,000.00.