In People v. Aspiras, the Supreme Court of the Philippines affirmed the conviction of Dominador Aspiras for murder, emphasizing the credibility of eyewitness testimony and the presence of treachery in the commission of the crime. The Court underscored that even if a judge inherits a case, the validity of the decision stands as long as the full record, including transcripts, is thoroughly reviewed. This ruling reinforces the importance of reliable witness accounts in criminal proceedings and clarifies how damages for loss of future income are calculated, providing a practical guide for similar cases.

Justice Denied: Did a Police Officer Abuse Power in a Political Rally Shooting?

The case revolves around the fatal shooting of Renato Lumague during a political rally in Pozorrubio, Pangasinan. Dominador Aspiras, a police officer, was identified as the shooter by two eyewitnesses. The trial court found Aspiras guilty of murder, citing treachery as a qualifying circumstance. Aspiras appealed, challenging the credibility of the eyewitnesses and questioning the basis for the civil damages awarded to the victim’s heirs. The Supreme Court was tasked with determining whether the evidence supported the conviction and whether the damages were properly assessed.

At the heart of the Supreme Court’s decision was the evaluation of the eyewitness accounts. The defense argued that the testimonies of Juanito Caballero and Victor Juguilon were unreliable. However, the Court emphasized that both witnesses had a clear view of the incident and were familiar with the accused, enhancing the credibility of their identification. The Court quoted the testimonies:

Direct Examination of Juanito Caballero:
Q: Will you please tell the Honorable Court who shot Renato Lomague?
A: It was Dominador Aspiras, sir.
Q: Is he the same Dominador Aspiras who is the accused in this case?
A: Yes sir.

Direct Examination of Victor Juguillon:
Q: Can you tell us who shot Renato Lumague?
A. Yes, sir, it was Dominador Aspiral (sic) alias Boy, Madam.

Building on this principle, the Court noted that inconsistencies in minor details, such as whether the assailant walked calmly or quickly, did not diminish the overall credibility of the witnesses. Such variations, the Court reasoned, could actually enhance the veracity of their testimonies by dispelling any suspicion of rehearsed accounts. The Court cited People vs. Sioc and Gonzales, GR No. 66508, November 24, 1999, to reinforce this point.

The defense presented an alibi, claiming that Aspiras was on duty in Las Piñas, Metro Manila, at the time of the shooting. To support this, they submitted a police logbook and presented fellow police officers as witnesses. However, the Supreme Court found inconsistencies in their testimonies and the logbook entries, casting doubt on the alibi. The Court pointed out that it was not physically impossible for Aspiras to be at the crime scene, given the relatively short distance between Manila and Pozorrubio, Pangasinan. The Court stated:

Alibi may be appreciated if the following requisites are present: a) proof of his presence at another place at the time of the perpetration of the offense, and b) impossibility for him to be at the scene of the crime. (People vs. Saban and Saban, GR No. 110559, November 24, 1999.)

Moreover, the Court highlighted the presence of treachery in the commission of the crime. The sudden and unexpected nature of the attack on Lumague, who was delivering a speech at a political rally, demonstrated that he had no opportunity to defend himself. The essence of treachery, according to the Court, lies in this swift and unforeseen assault on an unarmed victim without provocation. The Court referenced Delfin Abalos vs. Court of Appeals, RTC-Br. 38, Lingayen, Pangasinan, and People of the Philippines, GR No. 125434, December 22, 1999, p.10, to substantiate this finding.

Regarding the award of civil damages, the Supreme Court modified the amounts granted by the trial court. While it upheld the indemnity and moral damages, it adjusted the award for actual damages to include only those expenses supported by receipts. Furthermore, the Court recalculated the compensation for loss of future income, applying the formula:

2/3 x (80 – age of victim at the time of death) x (reasonable portion of the annual net income which would have been received as support by heirs).

This calculation resulted in a reduced award for loss of earning capacity, reflecting a more accurate assessment based on established legal principles. The Court determined that:

net earning capacity	=	2(80 – 48)		x	(P129,320 – 64,660)
		3
	=	2(32)	x	64,660
		3
	=	21.33	x	64,660
	=	P1,379,197.80

FAQs

What was the key issue in this case?	The key issue was whether the evidence presented by the prosecution was sufficient to convict Dominador Aspiras of murder beyond a reasonable doubt, particularly focusing on the credibility of eyewitness testimonies and the presence of treachery.
Why did the Supreme Court uphold the trial court’s decision?	The Supreme Court upheld the decision because it found the eyewitness testimonies credible and consistent, and it determined that the qualifying circumstance of treachery was present during the commission of the crime. Additionally, the alibi presented by the defense was deemed unconvincing due to inconsistencies and the physical possibility of the accused being at the crime scene.
What is the significance of treachery in this case?	Treachery is significant because it elevates the crime from homicide to murder, which carries a heavier penalty. The Court found that the sudden and unexpected attack on the victim, who was unarmed and speaking at a rally, constituted treachery, as he had no opportunity to defend himself.
How did the Court assess the credibility of the eyewitnesses?	The Court assessed the credibility of the eyewitnesses by considering their familiarity with the accused, their clear view of the incident, and the consistency of their testimonies. Minor inconsistencies were viewed as enhancing credibility rather than diminishing it.
What was the alibi presented by the accused, and why was it rejected?	The accused claimed he was on duty in Las Piñas at the time of the shooting. The alibi was rejected due to inconsistencies in the police logbook and testimonies of fellow officers, and the fact that it was physically possible for the accused to travel from Las Piñas to the crime scene.
How did the Supreme Court modify the award of civil damages?	The Supreme Court modified the award of civil damages by adjusting the amount for actual damages to include only those expenses supported by receipts. It also recalculated the compensation for loss of future income using a specific formula, resulting in a reduced award.
What is the formula used to calculate loss of future income?	The formula used to calculate loss of future income is: 2/3 x (80 – age of victim at the time of death) x (reasonable portion of the annual net income which would have been received as support by heirs). This formula considers the victim’s age, potential working years, and net income.
What are the practical implications of this ruling?	The ruling reinforces the importance of reliable eyewitness accounts in criminal proceedings and provides clarity on how damages for loss of future income are calculated. It also highlights that even if a judge inherits a case, the validity of the decision stands if the full record is thoroughly reviewed.

The Supreme Court’s decision in People v. Aspiras serves as a clear reminder of the importance of credible witness testimony and the impact of qualifying circumstances like treachery in criminal cases. The careful evaluation of evidence and the precise calculation of damages underscore the judiciary’s commitment to ensuring justice and fair compensation for victims of violent crimes.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Aspiras, G.R. No. 121203, April 12, 2000