In the case of People of the Philippines vs. Elinjer Corpuz y Daguio, the Supreme Court affirmed the conviction of the accused for murder, emphasizing the critical role of treachery in determining culpability. This decision underscores that a sudden and unexpected attack that deprives the victim of any chance to defend themselves constitutes treachery, a circumstance that elevates the crime to murder. The ruling ensures that perpetrators of such heinous acts are held fully accountable under the law, reinforcing the importance of protecting individuals from treacherous attacks.

When a Family Dispute Turns Deadly: Examining the Elements of Murder

The case revolves around the fatal shooting of Jerry Corpuz by his nephew, Elinjer Daguio Corpuz, following an altercation between Jerry and Elinjer’s brother, Porfirio. The prosecution presented evidence that Elinjer shot Jerry while Porfirio had him pinned to the ground. Elinjer, however, claimed the shooting was accidental during a struggle for a gun. The central legal question is whether the killing was attended by treachery, a qualifying circumstance that elevates homicide to murder under Philippine law.

The Supreme Court meticulously examined the elements of murder, as defined in Article 248 of the Revised Penal Code (RPC). This provision states that “any person who, not falling within the provisions of Article 246, shall kill another, shall be guilty of murder and shall be punished by reclusion perpetua to death if committed with any of the following attendant circumstances… With treachery, taking advantage of superior strength, with aid of armed men, or employing means to weaken the defense or of means or persons to insure or afford impunity.” The Court focused on whether the prosecution successfully proved that Elinjer was indeed the assailant and that the killing was committed with treachery.

The Court gave significant weight to the testimonies of the prosecution witnesses, particularly Ofelia Corpuz, the victim’s wife, and Jerick Corpuz, the victim’s son. Ofelia testified in detail about the events leading to the shooting, stating that she saw Elinjer approach her husband, who was already pinned down by Porfirio, and shoot him twice. Jerick corroborated his mother’s account, confirming that he saw Elinjer walking away from the scene with a gun in hand. The trial court found these testimonies to be “spontaneous, categorical and straightforward,” and the Supreme Court affirmed this assessment, highlighting that when a testimony is candid and direct, it is more likely to be truthful.

The defense argued that the shooting was an accident, occurring during a struggle for the gun. However, the Court rejected this claim, emphasizing the positive identification of Elinjer as the shooter. The Court noted that Elinjer’s actions – approaching the victim while he was incapacitated and shooting him twice – indicated a deliberate act rather than an accident. This conclusion was crucial in establishing Elinjer’s culpability for the crime.

Building on this, the Court addressed the critical element of treachery. Treachery exists when the offender employs means, methods, or forms in the execution of the crime that directly and especially ensure its execution without risk to himself arising from the defense which the offended party might make. The Court found that Elinjer’s act of shooting Jerry while he was pinned down by Porfirio effectively denied Jerry any chance to defend himself. This element of surprise and helplessness was central to the Court’s determination that treachery was present.

The Court contrasted the presence of treachery with the absence of evident premeditation. Evident premeditation requires a previous decision to commit the crime, an overt act indicating that the accused clung to his determination, and a sufficient lapse of time for reflection. In this case, the Court agreed with the lower courts that the prosecution had not sufficiently established evident premeditation. The killing appeared to be more spontaneous, arising from the ongoing altercation, rather than a planned event.

The Court then turned to the matter of the penalty. Under Article 248 of the RPC, as amended by Republic Act No. 7659, murder is punishable by reclusion perpetua to death. Given the absence of any aggravating circumstances, the Court affirmed the penalty of reclusion perpetua. Additionally, the Court addressed the monetary awards to be paid to the victim’s heirs. The Court sustained the grant of P75,000.00 as civil indemnity and increased the amounts for moral damages, exemplary damages, and temperate damages to P75,000.00, P75,000.00, and P50,000.00, respectively, aligning with prevailing jurisprudence. These amounts are also subject to an interest of six percent per annum from the finality of the judgment until fully paid.

Building on this comprehensive analysis, the Supreme Court’s decision in People vs. Corpuz provides critical insights into the application of criminal law principles, particularly regarding murder and its qualifying circumstances. The ruling underscores the importance of eyewitness testimony in establishing the facts of a crime and the significance of treachery in elevating homicide to murder. This case serves as a reminder that individuals who commit treacherous acts will be held accountable to the fullest extent of the law.

FAQs

What was the key issue in this case?	The central issue was whether the killing of Jerry Corpuz by Elinjer Corpuz constituted murder, specifically focusing on the presence of treachery as a qualifying circumstance. The court had to determine if the circumstances of the killing met the legal definition of treachery, thereby elevating the crime from homicide to murder.
What is the legal definition of treachery?	Treachery is defined as employing means, methods, or forms in the execution of a crime against persons that directly and especially ensure its execution without risk to the offender arising from the defense which the offended party might make. It involves a sudden and unexpected attack that deprives the victim of the opportunity to defend themselves.
What evidence did the prosecution present to prove Elinjer Corpuz was the assailant?	The prosecution presented eyewitness testimony from Ofelia Corpuz, the victim’s wife, and Jerick Corpuz, the victim’s son. Both witnesses testified that they saw Elinjer Corpuz shoot Jerry Corpuz, with Ofelia providing a detailed account of Elinjer approaching and shooting Jerry while he was pinned down.
Why did the Court reject the defense’s claim that the shooting was accidental?	The Court rejected the defense’s claim because the prosecution witnesses positively identified Elinjer Corpuz as the person who deliberately shot the victim. The circumstances of the shooting, where Elinjer approached the victim who was already incapacitated and shot him twice, indicated a deliberate act rather than an accident.
How did the Court differentiate between treachery and evident premeditation in this case?	The Court found that treachery was present because the shooting was sudden and unexpected, depriving the victim of any chance to defend himself. In contrast, evident premeditation was not proven because there was no sufficient evidence of a prior plan or enough time for Elinjer to reflect on the consequences before committing the act.
What was the final ruling of the Supreme Court?	The Supreme Court affirmed the Court of Appeals’ decision, finding Elinjer Corpuz guilty of murder and sentencing him to reclusion perpetua. The Court also ordered Elinjer to pay civil indemnity, moral damages, exemplary damages, and temperate damages to the victim’s heirs, with interest accruing from the finality of the judgment.
What monetary damages were awarded to the victim’s heirs?	Elinjer Corpuz was ordered to pay P75,000.00 as civil indemnity, P75,000.00 as moral damages, P75,000.00 as exemplary damages, and P50,000.00 as temperate damages. These amounts are subject to an interest of six percent per annum from the finality of the decision until fully paid.
What is the significance of this case in Philippine criminal law?	This case reinforces the importance of treachery as a qualifying circumstance in murder cases. It highlights that a sudden and unexpected attack that deprives the victim of any chance to defend themselves constitutes treachery, ensuring that perpetrators of such acts are held fully accountable under the law.

The Supreme Court’s decision in People vs. Corpuz serves as a stark reminder of the severe consequences of violent acts, particularly those committed with treachery. This case underscores the Philippine justice system’s commitment to protecting individuals from treacherous attacks and ensuring that perpetrators are brought to justice.

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: THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ELINJER CORPUZ Y DAGUIO, ACCUSED-APPELLANT., G.R. No. 220486, June 26, 2019