G.R. No. L-73464 August 9, 1988
People of the Philippines vs. Edmundo de Guzman @ Jojo, Perfecto Gueta and Joel Gueta; Edmundo de Guzman, appellant.

FACTS

The prosecution’s evidence established that on the evening of January 29, 1985, appellant Edmundo de Guzman was seen near the victim’s store and house in Bacoor, Cavite. He was later observed carrying a long gun and approaching the house where Luis Baliber, Sr. was watching television with his children. De Guzman entered, pointed his gun at a witness, and then fired multiple shots at the reclining and defenseless Baliber, Sr., who sustained fifteen gunshot wounds. Witnesses, including the victim’s wife and brother-in-law, positively identified de Guzman as the assailant. The cases against his co-accused, Perfecto and Joel Gueta, were dismissed for lack of conspiracy.
The defense presented an alibi, claiming de Guzman was at home drinking with a neighbor from 6 p.m. to 11 p.m. because his wife was giving birth and his child was sick. He denied being the assailant, suggesting the killer was taller and differently dressed. De Guzman also testified he was arrested unexpectedly when he visited his detained relatives at the municipal jail.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt the identity of Edmundo de Guzman as the perpetrator of the murder of Luis Baliber, Sr., and whether the qualifying circumstance of treachery was present.

RULING

The Supreme Court affirmed the conviction for Murder but modified the penalty. The Court found the positive identification by eyewitnesses, who had no ill motive to testify falsely, to be credible and sufficient to establish de Guzman’s guilt beyond reasonable doubt. Their testimonies were consistent and detailed, describing his approach, weapon, and actions. The defense of alibi, uncorroborated by other evidence and inherently weak, could not prevail over this positive identification. The Court upheld the trial court’s finding of treachery (alevosia). The attack was sudden, executed from behind while the victim was peacefully watching television inside his own home, rendering him completely defenseless and unable to offer any resistance or retaliation. This manner of execution was deliberately adopted to ensure the killing without risk to the assailant. However, the Supreme Court reduced the penalty from death to an indeterminate sentence of 10 years and 1 day of prision mayor, as minimum, to 18 years and 8 months and 1 day of reclusion temporal, as maximum, in line with prevailing jurisprudence on the proper imposable penalty.