PEOPLE vs.

BELTRAN
61 SCRA 463
FACTS: The accused-appellant was found guilty of murder. The sentenced to him was reclusion
perpetua and to indemnify the heirs of Clemente Pingol in the sum of P6,000.00.
On the evening of September 21, 1963, Clemente Pingol was fatally shot from behind
with a shotgun. Only on September 30, 1963, Ernesto and Raymundo Dua, brothers, implicated
Amelito Beltran as the person who fatally shot the deceased. The two brothers gave a
substantially identical testimony that Beltran walked past their house carrying a shotgun on his
shoulder and proceeded directly towards the house and upon reaching a coconut tree in front of
the house, concealed himself behind said tree and fired with his shotgun at Clemente Pingol.
Beltran fled from the scene after shooting the victim taking the same route, passing near the
porch of the house of the witnesses. The defense of alibi was interposed by Beltran, he was in
Barrio Lucbon on the same day until early morning of September 22, attending to the making of
coprax. Beltran testimony was corroborated by Realino Botoy. The appellant questioned the
credibility of the witnesses testimony, why he will pass in front of someone while carrying a
gun? Why he will take the long route when there is shortcut? Why doesn't the witnesses warned
the victim? Why the witnesses doesn't inform the police while they are conducting the
investigation on September 22?
ISSUE: Whether or not the accused-appellant should be held liable by the testimonies and
motive?
HELD: The decision is reversed. The accused is acquitted.
It is true that motive is not essential for the conviction of an accused where there is no doubt as
to his identity as the culprit, but where the identification proceeds from an unreliable source and
the testimony is inconclusive and not free from doubt, then evidence of motive becomes
necessary. In the case, the identification of the appellant as the assailant of the victim is not
convincing. In view of the unreliability of the identification of appellant, the defense of alibi
interposed by him, therefore, assumes importance.
While it is true that an "alibi is the weakest defense that an accused can avail of, it acquires
commensurate strength where, as in this case, no positive and proper identification has been
made by the witnesses of the offender. The prosecution has the onus probandi in establishing the
guilt of the accused and the weakness of the defense does not relieve it of this responsibility."
The Supreme Court is not satisfied that the constitutional presumption of innocence accorded to
appellant has been overcome. To overcome that presumption, the guilt of appellant must be
shown beyond reasonable doubt. As Justice Fernando emphasized: "The proof against him must
survive the test of reason; the strongest suspicion must not be permitted to sway judgment. The

conscience must be satisfied that on the defendant could be laid the responsibility for the offense
charged; that not only did he perpetrate the act but that it amounted to a crime." 8

PEOPLE vs. BALINAS

202 SCRA 516
FACTS: The accused-appellant was found guilty of murder as charged qualified by treachery.
The sentenced to him was reclusion perpetua and to pay the heirs of Columban M. Sayson.
On January 7, 2000, Romeo Mateo (sole witness) heard Jose Balinas Sr. and Jose Balinas Jr.
fighting on how much money should they put on bet. Columban Sayson(deceased) intervened
and gave his suggestion on the bet. Sayson and Balinas Jr. argued. Sensing a conflict, Mateo
went to nearby store while the appellant went back to his house. Later, he saw Balinas Jr. stabbed
Sayson twice on chest. Mateo was situated four arms length away from the scene of the crime.
Sayson died. Balinas Jr. voluntary surrendered. He admitted the stabbing but he invoked selfdefense. He related that Sayson waylaid him by the store and started beating him. He fought back
and stabbed Sayson.
ISSUE: Whether or not the appellant acted in self-defense(honest mistake of fact)?
Whether or not the killing was attended by treachery?
HELD: The decision is affirmed with modification.
Time and again, this Court has ruled that the testimony of a sole eyewitness is sufficient to
support a conviction so long as it is clear, straightforward and worthy of credence by the trial
court.
In light of the established evidence against appellant, his theory of self-defense falters. While the
cardinal rule in criminal law is that the prosecution has the burden of proving the guilt of the
accused, the rule is reversed where the accused admits committing the crime, but only in defense
of one's self. In interposing self-defense, appellant admits authorship of the killing and the
burden of proof is shifted to him to establish that killing was justified. Appellants account of the
incident and his subsequent plea of self-defense hardly deserve consideration. His testimony is
not only uncorroborated but extremely doubtful.
The courts below correctly appreciated the circumstance of treachery. The essence of treachery is
the sudden and unexpected attack on an unsuspecting victim by the perpetrator of the crime,
depriving the victim of any chance to defend himself or repel the aggression, thus insuring its
commission without risk to the aggressor and without any provocation on the part of the victim.