G.R. No. 84448 February 7, 1990
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SALVADOR BADUYA Y TIBUS, defendant-appellant.

FACTS

The case originated from a volleyball game on December 29, 1984, in Barangay San Antonio, Milaor, Camarines Sur. Appellant Salvador Baduya bet on the home team, which lost to a visiting team cheered by the Brusas and Euste families. After the game, the Brusas and Euste cousins jeered at Baduya, who responded by pushing a relative of the group. The following day, Baduya claimed he received threats from the cousins, prompting him to stay home. On January 1, 1985, a separate altercation occurred at a store between the Lumerio brothers (relatives of Baduya) and the Euste brothers, resulting in Ramon Euste being stabbed. A jeepney was summoned to transport the wounded Ramon to the hospital, accompanied by his brother Rafael and cousin Ariel Brusas.
While en route, the jeepney encountered a group that included Baduya, his son Francisco (armed with a bolo), and Baduya himself carrying a rifle. Francisco signaled the jeepney to stop and struck its windshield with his bolo when it did not. As the vehicle passed about five meters away, Baduya pointed his gun at the passengers and fired, hitting both Ariel Brusas and Ramon Euste. Ariel died from his wounds, while Ramon survived after surgery. Baduya and his son were charged with the complex crime of murder and frustrated murder. The trial court convicted Baduya but acquitted his son, Francisco, on reasonable doubt.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that Salvador Baduya was the perpetrator of the shooting that killed Ariel Brusas and wounded Ramon Euste, thereby committing the complex crime of murder with frustrated murder.

RULING

The Supreme Court affirmed the conviction. The Court found the prosecution’s version of events, supported by multiple eyewitnesses including Rafael Euste, to be credible and consistent. The defense’s claim that Baduya was not present at the shooting was rejected. The Court held that the relationship of a witness to the victim does not automatically impair credibility, especially when the testimony is logical, corroborated by other evidence, and aligned with medical findings. The alleged inconsistencies in the witnesses’ accounts were deemed minor and did not affect the core narrative of the shooting.
The Court also found Baduya’s motive established. His resentment from the public ridicule after the volleyball game and the subsequent fight involving his relatives provided sufficient impetus for the assault. The shooting was characterized by treachery, as the victims inside the moving jeepney were defenseless and unable to retaliate, qualifying the killing as murder. The act of firing a single shot that hit two victims constituted a complex crime. The trial court’s factual findings were accorded respect, as no substantial reason was shown to overturn them. Thus, the penalty of reclusion perpetua and the awarded indemnities were upheld.