G.R. No. L-19114 March 18, 1966
People of the Philippines, plaintiff-appellee, vs. Raymundo de Villa, defendant-appellant.

FACTS

On July 29, 1959, in Talisay, Batangas, a BTCO bus driven by Modesto Malabanan was forced to stop when tree branches blocked the road in sitio Ticub. The conductor, Bonifacio Umandal, along with Agripino Reyes and another passenger, alighted to remove the obstructions. While they were doing so, successive gunshots were heard. Malabanan saw appellant Raymundo de Villa about five meters away, facing him and holding a carbine, and saw Umandal fall to the ground. Appellant then challenged the male bus occupants to come down before running away. Umandal was found dead. Empty carbine shells were found at the scene. Appellant was apprehended on August 12, 1959, and executed a sworn confession before the Justice of the Peace of Nasugbu, Batangas, admitting he shot Umandal and indicating where he hid the carbine. The firearm was recovered from that location. Ballistic examination confirmed the empty shells were fired from the recovered carbine. The autopsy established death was due to the gunshot wounds. Appellant was charged with murder, convicted, and sentenced to reclusion perpetua.

ISSUE

Whether the trial court erred in convicting appellant of murder based on the evidence presented, including his confession and the testimonies of eyewitnesses.

RULING

The Supreme Court affirmed the conviction. Appellant’s claim that his confession was involuntary was rejected as self-serving and outweighed by its corroboration with other evidence: positive identification by eyewitnesses Malabanan and Reyes who knew him personally and saw him with the carbine at the scene, the recovery of the carbine from the location he specified, and the ballistic match of the shells. His alibi was untenable given the proximity of his house to the crime scene and the positive identification. The medical testimony established the fatal wounds were caused by the carbine. The decision was in accordance with law and evidence.