ASG Law

Tag: Homicide

  • Self-Defense Claim Fails: Understanding Unlawful Aggression in Philippine Homicide Law

    In a ruling that clarifies the boundaries of self-defense in homicide cases, the Supreme Court affirmed the conviction of Rezor Juanillo Manzano, Jr. for murder. The Court emphasized that for a claim of self-defense to succeed, the accused must first demonstrate that the victim committed unlawful aggression. This decision underscores the importance of proving imminent danger to one’s life before resorting to lethal force, providing a crucial guide for understanding justifiable self-defense under Philippine law.

    Stones, Cigarettes, and Fatal Wounds: Did Self-Defense Justify the Stabbing of Lucio Silava?

    The case of People of the Philippines v. Rezor Juanillo Manzano, Jr. began with a seemingly simple request for cigarettes, escalating into a brutal murder. Rezor Juanillo Manzano, Jr. and his brother, Resurrecion, were accused of fatally stabbing Lucio Silava. Rezor admitted to the killing but claimed self-defense, alleging that Lucio initiated the aggression by throwing stones at his house and later attacking him with a knife. The prosecution, however, presented a different narrative, asserting that the Manzano brothers conspired to kill Lucio in his store. The central legal question was whether Rezor’s actions were justified under the principle of self-defense, or if he was guilty of murder.

    The Regional Trial Court (RTC) and the Court of Appeals (CA) both found Rezor guilty of murder, a decision that hinged on the credibility of witnesses and the assessment of evidence. The Supreme Court, in its review, affirmed these findings, emphasizing the principle that the findings of the trial court regarding the credibility of witnesses should be respected, especially when affirmed by the appellate court. The Court noted that it is a general rule in criminal cases that an examination of the entire records of a case may be explored for the purpose of arriving at a correct conclusion. It is for this reason that the Court has painstakingly reviewed the records of this case; yet, it found no reason to depart from the well-entrenched rule that the findings of the RTC as to the credibility of witnesses should not be disturbed considering the absence of any showing that it had overlooked a material fact that otherwise would change the outcome of the case or had misunderstood a circumstance of consequence in their evaluation of the credibility of the witnesses. The testimony of Victoria, Lucio’s spouse, was particularly critical, identifying Rezor and his brother as the assailants. The Court found Victoria’s testimony positive, convincing, and straightforward.

    The accused-appellant tried to dent the credibility of Victoria by asserting that she did not actually see the scuffle between him and Lucio as verified by her admission during the cross-examination by the defense. However, the contention of the accused-appellant is without merit. The records bear out that Victoria admitted that right after she heard Lucio utter “What wrong did I commit,” she immediately went to the kitchen and found her husband leaning on the kitchen door, bloodied, while the accused-appellant and Resurrecion were stabbing him. The Supreme Court stated:

    It was clear from the testimony of Victoria that she was able to personally witness when the accused-appellant and Resurrecion assaulted Lucio; and that she could not be mistaken as to the assailants’ identity since the place where the crime happened was well-lighted.

    Building on this principle of credibility, the Court addressed Rezor’s claim of self-defense. The law dictates that anyone who pleads a justifying circumstance under Article 11 of the Revised Penal Code admits to the commission of acts, which would otherwise engender criminal liability. Self-defense requires the accused to prove that there was an unlawful and unprovoked attack that endangered their life, forcing them to inflict severe wounds upon the assailant. The Supreme Court underscored that self-defense, to be successfully invoked, must be proven by clear and convincing evidence that excludes any vestige of criminal aggression on the part of the person invoking it.

    To establish self-defense, Rezor had to demonstrate three critical elements: unlawful aggression on the part of the victim, reasonable necessity of the means employed to prevent or repel such aggression, and lack of sufficient provocation on the part of the person resorting to self-defense. The absence of even one of these elements would invalidate the claim of self-defense. The Court, in its analysis, focused primarily on the element of unlawful aggression, stating:

    Unlawful aggression on the part of the victim is the primordial element of the justifying circumstance of self-defense. Without unlawful aggression, there can be no justified killing in defense of oneself.

    The Court highlighted that the aggression must put in real peril the life or personal safety of the person defending himself, and the peril must not be an imagined or imaginary threat. The evidence presented by Rezor failed to convince the Court that Lucio initiated an unlawful attack. The prosecution’s evidence, particularly the testimony of Victoria and the physical evidence of blood splatters inside the store, contradicted Rezor’s version of events. Where the physical evidence on record runs counter to the testimonies of witnesses, the primacy of the physical evidence must be upheld. Furthermore, the Court noted that Rezor had neither witness nor evidence to fortify his claim that the unlawful aggression started with Lucio.

    It is also important to remember that, a plea of self-defense is controverted by the nature, number, and location of the wounds inflicted on the victim, since the gravity of said wounds is indicative of a determined effort to kill and not just to defend. The postmortem examination revealed that Lucio sustained fifteen wounds, four of which were fatal, indicating an undeniable intent on the part of Rezor to kill. Given these circumstances, the Supreme Court concluded that Rezor’s claim of self-defense was untenable, leading to the determination of the offense committed. The Court then addressed whether the crime was murder or homicide, focusing on the presence of qualifying circumstances such as treachery and abuse of superior strength. To warrant a conviction for the crime of murder, the following essential elements must be present: (a) that a person was killed; (b) that the accused killed him or her; (c) that the killing was attended by any of the qualifying circumstances mentioned in Art. 248 of the RPC; and (d) that the killing is not parricide or infanticide. Treachery is present when the offender commits any of the crimes against a person, employing means, methods, or forms in the execution thereof which tend directly and specially to insure its execution, without risk to himself arising from the defense which the offended party might make.

    The Court found that the accused-appellant and Resurrecion deliberately made it appear to Victoria and Lucio on the night of 19 March 2010, that their main purpose in coming to the store was to buy cigarettes. They came at night when neighbors were probably asleep which would make it impossible for them to lend assistance to Lucio. The Court also determined that since treachery qualified the crime to murder, the generic aggravating circumstance of abuse of superior strength is necessarily included in the former. These findings led the Supreme Court to affirm Rezor’s conviction for murder. Finally, the Supreme Court addressed the issue of voluntary surrender as a mitigating circumstance. For voluntary surrender to be appreciated as a mitigating circumstance, the following elements must be present, to wit: (1) the accused has not been actually arrested; (2) the accused surrenders himself to a person in authority or the latter’s agent; and (3) the surrender is voluntary. Records showed that it was Reno who went to the Hamtic police station to request that they take custody of the accused-appellant who was then in his house. Undoubtedly, when the police went to Reno’s house at San Angel, San Jose, Antique, it was for the purpose of arresting the accused-appellant and not because he was surrendering to them voluntarily.

    FAQs

    What was the key issue in this case? The key issue was whether Rezor Juanillo Manzano, Jr. acted in self-defense when he stabbed and killed Lucio Silava, or if he was guilty of murder. The court examined the presence of unlawful aggression and other elements of self-defense.
    What is unlawful aggression? Unlawful aggression is a physical or material attack, or an imminent threat thereof, that endangers the life or personal safety of the person defending themselves. This is the most important element in claiming self-defense.
    What did the prosecution argue? The prosecution argued that Rezor and his brother conspired to kill Lucio Silava inside his store. They said the brothers feigned wanting to buy cigarettes to gain entry.
    Why did the Supreme Court reject the self-defense claim? The Supreme Court rejected the self-defense claim because Rezor failed to prove that Lucio committed unlawful aggression against him. The evidence and witness testimony suggested the opposite.
    What evidence supported the finding of murder? The presence of treachery, established by the sudden and unexpected nature of the attack, qualified the killing as murder. The severe wounds inflicted on Lucio also indicated an intent to kill.
    Did Rezor’s surrender affect the outcome? No, the court did not consider Rezor’s surrender as a mitigating circumstance. It was because his surrender was not considered voluntary, as the police were already on their way to arrest him.
    What was the final ruling of the Supreme Court? The Supreme Court affirmed the lower court’s decision, finding Rezor Juanillo Manzano, Jr. guilty of murder and sentencing him to reclusion perpetua. The court also awarded damages to the heirs of Lucio Silava.
    What damages were awarded to the victim’s heirs? The heirs of Lucio Silava were awarded civil indemnity, moral damages, exemplary damages, and temperate damages. The total was P275,000.00, plus interest at a rate of 6% per annum from the finality of the decision until fully paid.

    The Supreme Court’s decision in People v. Rezor Juanillo Manzano, Jr. serves as a stark reminder of the stringent requirements for proving self-defense in Philippine law. The ruling reinforces the principle that unlawful aggression is the cornerstone of self-defense claims, and that the burden of proof lies heavily on the accused. This case further clarifies the importance of credible witness testimony and physical evidence in determining the facts of a crime, providing a comprehensive analysis of justifiable self-defense and its limitations.

    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 of the Philippines, Plaintiff-Appellee, v. Rezor Juanillo Manzano, Jr., Accused-Appellant, G.R. No. 217974, March 05, 2018

  • Self-Defense Claim Fails: Supreme Court Upholds Conviction in Parricide and Homicide Case

    The Supreme Court affirmed the conviction of Arsenio Endaya, Jr. for parricide and homicide, underscoring that self-defense claims require compelling evidence of unlawful aggression, reasonable means of defense, and lack of sufficient provocation. This decision reinforces the high burden of proof placed on defendants who admit to killing another but argue they acted in self-defense, clarifying the stringent standards Philippine courts apply in evaluating such claims. The ruling ensures accountability for violent acts while providing clear guidance on the legal requirements for a valid self-defense argument.

    When Marital Strife Turns Deadly: Unpacking a Failed Plea of Self-Defense

    The case of The People of the Philippines vs. Arsenio Endaya, Jr. revolves around the tragic events of November 21, 1999, where Arsenio Endaya, Jr. was accused of fatally stabbing his wife, Jocelyn Quita-Endaya, and his mother-in-law, Marietta Bukal-Quita. Endaya admitted to the killings but argued he acted in self-defense after being attacked by Jocelyn’s son, Jennifer de Torres, during an attempt to reconcile with his wife. This plea necessitated the Court to examine whether Endaya met the stringent criteria for self-defense under Philippine law, specifically the presence of unlawful aggression, reasonable necessity of the means employed to prevent or repel it, and lack of sufficient provocation on his part.

    At trial, the prosecution presented Jennifer de Torres’s testimony, who recounted witnessing Endaya stabbing his mother and grandmother. The defense, on the other hand, relied on Endaya’s testimony that he acted in self-defense after being attacked with a bolo by De Torres, leading to the accidental stabbing of Jocelyn and Marietta. The Regional Trial Court (RTC) found Endaya guilty, a decision affirmed with modifications by the Court of Appeals (CA). Both courts found Endaya’s self-defense claim unconvincing, citing the multiple stab wounds inflicted on the victims and inconsistencies in Endaya’s account.

    The Supreme Court’s analysis centered on the elements of self-defense as outlined in Article 11 of the Revised Penal Code. To justify his actions, Endaya needed to demonstrate unlawful aggression from the victims, reasonable means of defense, and lack of provocation from his side. The Court, however, found Endaya’s evidence lacking, particularly concerning the element of unlawful aggression. As the Court has emphasized,

    For unlawful aggression to be appreciated there must be an actual, sudden and unexpected attack or imminent danger thereof, not merely a threatening or intimidating attitude.

    Endaya’s account of being hacked by De Torres was not corroborated by the anatomical sketch presented as evidence, which only showed minor injuries inconsistent with a bolo attack. Furthermore, the Supreme Court noted the implausibility of Endaya’s claim that he mistakenly stabbed both Jocelyn and Marietta multiple times in self-defense. The presence of four stab wounds on each victim undermined the claim that his actions were a reasonable response to an immediate threat, thus, the court emphasized that

    If at all, these stab wounds demonstrate a criminal mind resolved to end the life of the victims.

    The Court also addressed the appropriate penalties for parricide and homicide. For parricide, the penalty was reclusion perpetua, while for homicide, the appellate court correctly modified the penalty to reflect the mitigating circumstance of voluntary surrender. The Indeterminate Sentence Law was applied, setting the minimum penalty at six years and one day of prision mayor and the maximum at twelve years and one day of reclusion temporal. The Court further adjusted the monetary awards to conform to prevailing jurisprudence, increasing the moral damages for the heirs of Jocelyn and awarding exemplary damages.

    The Supreme Court underscored that when a defendant admits to the killing but claims self-defense, the burden of proof shifts to them to demonstrate the validity of their claim. This principle is well-established in Philippine jurisprudence. In this case, Endaya failed to provide clear and convincing evidence to support his self-defense plea, leading to the affirmation of his conviction. This failure highlights the importance of credible and consistent evidence when asserting self-defense.

    This case serves as a reminder of the rigorous standards applied by Philippine courts when evaluating self-defense claims. The requirements of unlawful aggression, reasonable means of defense, and lack of provocation must be substantiated with concrete evidence, not merely assertions. The ruling reinforces the principle that individuals are accountable for their actions unless they can demonstrate a lawful justification. Moreover, it highlights the crucial role of evidence in determining the outcome of criminal cases, emphasizing that unsubstantiated claims will not suffice to overturn a conviction.

    FAQs

    What was the key issue in this case? The key issue was whether Arsenio Endaya, Jr. acted in self-defense when he killed his wife and mother-in-law, thus, exempting him from criminal liability for parricide and homicide. The Court assessed whether the elements of self-defense were sufficiently proven by the defense.
    What are the elements of self-defense in the Philippines? The elements of self-defense are unlawful aggression on the part of the victim, reasonable necessity of the means employed to prevent or repel it, and lack of sufficient provocation on the part of the person defending themselves. All three elements must be present for a successful claim of self-defense.
    What happens when a defendant claims self-defense? When a defendant claims self-defense, the burden of proof shifts to them. They must present clear and convincing evidence to demonstrate that their actions were justified under the law.
    Why did the Supreme Court reject Endaya’s self-defense claim? The Court rejected Endaya’s claim because he failed to prove unlawful aggression from the victims. The evidence presented was inconsistent with his account of being attacked, and the multiple stab wounds on the victims indicated a criminal intent rather than self-preservation.
    What is the significance of the anatomical sketch in this case? The anatomical sketch, which was presented by the defense to prove self-defense, undermined Endaya’s credibility as it showed only minor injuries, contradicting his claim of being severely attacked with a bolo. This discrepancy weakened his argument and contributed to the rejection of his self-defense plea.
    What penalties were imposed on Endaya? Endaya was sentenced to reclusion perpetua for parricide and an indeterminate sentence for homicide, ranging from six years and one day of prision mayor to twelve years and one day of reclusion temporal. He was also ordered to pay civil indemnity, moral damages, and exemplary damages to the victims’ heirs.
    How did the Court modify the monetary awards? The Court increased the moral damages awarded to the heirs of Jocelyn Quita-Endaya and awarded exemplary damages, in accordance with prevailing jurisprudence. All monetary awards were subjected to an interest rate of six percent per annum from the finality of the decision until full payment.
    What is the Indeterminate Sentence Law? The Indeterminate Sentence Law requires courts to impose a minimum and maximum term of imprisonment, rather than a fixed sentence. This allows for parole consideration after the minimum term is served, based on the prisoner’s behavior and rehabilitation.

    In conclusion, the Supreme Court’s decision in People vs. Endaya reaffirms the strict standards for claiming self-defense and emphasizes the importance of presenting credible evidence to support such claims. This case serves as a guide for understanding the legal requirements for self-defense and the consequences of failing to meet those requirements.

    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. ARSENIO ENDAYA, JR. Y PEREZ, ACCUSED-APPELLANT, G.R. No. 225745, February 28, 2018

  • Unraveling Conspiracy: Establishing Guilt Beyond Reasonable Doubt in Homicide Cases

    In Roble Barbosa and Ramdy Barbosa v. People of the Philippines, the Supreme Court affirmed the conviction of the petitioners for homicide, emphasizing how circumstantial evidence can establish guilt beyond a reasonable doubt. The Court underscored that even in the absence of direct evidence, a combination of circumstances can sufficiently prove the elements of a crime. This decision clarifies the application of circumstantial evidence in Philippine criminal law, particularly in establishing conspiracy and intent in homicide cases, shaping standards for evidence evaluation in the Philippine legal system.

    Family Feud or Fatal Conspiracy? The Barbosas’ Day of Reckoning

    The case revolves around the death of Artemio Betita, Jr., allegedly at the hands of Roble Barbosa and his son, Ramdy Barbosa. The prosecution presented evidence indicating a history of rivalry between the victim and the accused, culminating in a fatal shooting. The Regional Trial Court (RTC) initially convicted the Barbosas of homicide, a decision later affirmed by the Court of Appeals (CA). The petitioners challenged the reliability of the testimony and denied any conspiracy, bringing the case before the Supreme Court. This scenario sets the stage for examining how Philippine courts assess circumstantial evidence and determine guilt in cases of homicide.

    At the heart of this case lies the legal principle of establishing guilt through circumstantial evidence. The Supreme Court reiterated the requisites for circumstantial evidence to warrant a conviction, emphasizing that there must be more than one circumstance, the facts from which the inferences are derived must be proven, and the combination of all circumstances must produce a conviction beyond reasonable doubt. Citing the Rules of Court, the Supreme Court emphasized the necessity of a stringent evaluation of evidence, ensuring that each piece of circumstantial evidence contributes to a coherent and convincing narrative of guilt.

    RULES OF COURT, Rule 133, Sec. 4: Circumstantial evidence is sufficient for conviction if (a) There is more than one circumstance; (b) The facts from which the inferences are derived are proven; and (c) The combination of all the circumstances is such as to produce a conviction beyond a reasonable doubt.

    In the Barbosa case, the Court meticulously outlined the chain of circumstances that led to the conviction. These included the victim’s apprehensive statement just before the incident, the challenge issued to the victim to come outside, the sound of gunshots, the presence of the petitioners holding firearms near the crime scene, and Ramdy’s subsequent flight. These circumstances, when viewed together, formed an unbroken chain that pointed to the petitioners’ involvement in the crime. Each circumstance, independently verified and logically connected, contributed to a cohesive narrative that implicated the Barbosas in Artemio Betita, Jr.’s death.

    The concept of conspiracy also played a significant role in the Court’s decision. Conspiracy, in legal terms, exists when two or more persons come to an agreement concerning the commission of a crime and decide to commit it. The Court inferred conspiracy from the coordinated actions of Roble and Ramdy Barbosa. They were both armed, strategically positioned, and ceased their assault only after the victim’s daughter pleaded for them to stop. This coordinated behavior suggested a common design to commit the crime, reinforcing the conclusion that the petitioners acted in concert.

    Furthermore, the Court addressed the issue of damages, particularly the award of actual damages by the lower courts. The Supreme Court highlighted that actual damages must be proven with competent evidence, such as receipts, to justify an award. In the absence of such proof, the Court awarded temperate damages, which are appropriate when the fact of loss is established but the exact amount cannot be determined. This adjustment reflects the Court’s adherence to the principles of evidence and the proper quantification of damages in criminal cases.

    People v. Villar, 757 Phil. 675, 684 (2015): To justify an award of actual damages, there must be competent proof of the actual amount of loss. Credence can be given only to claims which are duly supported by receipts.

    The decision also underscores the importance of witness credibility. The Court noted that there was no evidence to suggest that the witness, Betita, was motivated by any improper motive. Absent any compelling reason to doubt her testimony, the Court accorded it full faith and credence. This principle highlights the judiciary’s reliance on the integrity and objectivity of witnesses in establishing the facts of a case, reinforcing the importance of truthful testimony in the pursuit of justice.

    The Supreme Court modified the penalty imposed by the lower courts, adjusting the maximum period of the indeterminate sentence. This modification reflects the Court’s commitment to ensuring that the sentence aligns with the provisions of the Revised Penal Code and relevant jurisprudence. Additionally, the Court awarded moral damages to the heirs of the victim, recognizing the emotional suffering and grief caused by the crime. The imposition of interest on all damages from the date of finality of the decision further underscores the Court’s intention to provide just and equitable compensation to the aggrieved party.

    Moreover, the Supreme Court emphasized the deletion of attorney’s fees and litigation expenses, since no separate civil action to recover civil liability has been filed or when exemplary damages are awarded in this criminal action for homicide. Citing Heirs of Raymundo Castro v. Bustos, 136 Phil. 553, 562 (1969), the Court was therefore correct for the RTC to award attorney’s fees and litigation expenses since these circumstances do not exist in this criminal action for homicide.

    FAQs

    What was the key issue in this case? The key issue was whether the circumstantial evidence presented by the prosecution was sufficient to prove the guilt of Roble and Ramdy Barbosa beyond a reasonable doubt for the crime of homicide.
    What is circumstantial evidence? Circumstantial evidence is indirect evidence that implies a fact, from which a court can reasonably infer the existence of another fact. It requires that there be more than one circumstance, the facts from which the inferences are derived are proven and the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.
    What is the legal definition of conspiracy? Conspiracy exists when two or more persons come to an agreement concerning the commission of a crime and decide to commit it. It requires a common design and coordinated actions among the conspirators.
    Why did the Court modify the award of damages? The Court modified the award of damages because the actual damages were not supported by receipts, and the attorney’s fees and litigation expenses were improperly awarded, but awards moral damages to the heirs of the victim, recognizing the emotional suffering and grief caused by the crime.
    What are temperate damages? Temperate damages are awarded when the court is convinced that there has been such a loss suffered, but proof of the exact amount of loss cannot be produced. These damages are considered reasonable compensation.
    What was the significance of the witness testimony in this case? The witness testimony was significant because it provided a direct link between the petitioners and the crime scene. The Court deemed the testimony credible due to the absence of any improper motive on the part of the witness.
    What was the final ruling of the Supreme Court? The Supreme Court denied the petition for review and affirmed the Court of Appeals’ decision finding the petitioners guilty of homicide, with modifications to the penalty and the award of damages.
    What is the implication of this ruling for future cases? This ruling reinforces the principle that circumstantial evidence, when properly evaluated, can be sufficient to establish guilt beyond a reasonable doubt. It also underscores the importance of proving actual damages with competent evidence.

    The Barbosa v. People case serves as a clear illustration of how Philippine courts evaluate circumstantial evidence and establish guilt in criminal cases. It underscores the importance of a cohesive narrative, credible witness testimony, and adherence to the rules of evidence in the pursuit of justice. This case significantly contributes to the development of Philippine jurisprudence on evidence and criminal law.

    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: ROBLE BARBOSA AND RAMDY BARBOSA, PETITIONERS, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT., G.R. No. 207193, July 24, 2017

  • Circumstantial Evidence and Conspiracy in Homicide Cases: Establishing Guilt Beyond Reasonable Doubt

    The Supreme Court in Barbosa v. People affirmed the conviction of Roble and Ramdy Barbosa for homicide, emphasizing the role of circumstantial evidence and conspiracy in establishing guilt beyond reasonable doubt. The court underscored that even without direct eyewitness testimony, a series of interconnected circumstances can sufficiently prove culpability. This ruling reinforces the principle that the prosecution can secure a conviction based on a comprehensive analysis of the evidence, demonstrating a clear and logical connection between the accused’s actions and the crime committed. The decision serves as a reminder of the probative value of circumstantial evidence in criminal proceedings.

    From Business Rivalry to Fatal Gunshots: Can Circumstantial Evidence Seal a Homicide Conviction?

    The case originated from an information filed against Roble and Ramdy Barbosa for the death of Artemio Betita, Jr. The prosecution presented evidence indicating a history of rivalry between the Barbosas and the victim, culminating in a fatal shooting. The Regional Trial Court (RTC) found the Barbosas guilty of homicide, a decision later affirmed by the Court of Appeals (CA). The RTC considered several pieces of circumstantial evidence, including the proximity of their houses, business rivalry, a prior altercation, and the presence of the Barbosas armed near the crime scene shortly after the shooting. This led to the finding that they were responsible for Betita’s death.

    The Barbosas appealed, questioning the reliability of the testimony and denying the existence of a conspiracy. The Supreme Court, however, found no merit in their arguments. The Court reiterated the elements of homicide, noting that the prosecution successfully established that Artemio Betita, Jr. was killed, the accused caused his death without justification, they intended to kill him (presumed), and the killing was not qualified as murder, parricide, or infanticide. The victim’s death certificate confirmed the gunshot wound as the cause of death, and witnesses placed the Barbosas at the scene with firearms immediately after the incident.

    The Supreme Court emphasized the significance of circumstantial evidence in establishing the guilt of the accused. It reiterated that circumstantial evidence is sufficient for conviction if: (1) there is more than one circumstance; (2) the facts from which the inferences are derived are proven; and (3) the combination of all circumstances produces a conviction beyond reasonable doubt. The Court found that the circumstances presented in this case met these requisites, forming an unbroken chain that led to the logical conclusion that the Barbosas committed the crime of homicide. The Court outlined seven key pieces of circumstantial evidence.

    First, shortly before the shooting, the victim was heard muttering about envious people. Second, a man challenged the victim to come out of his house. Third, gunshots rang out immediately after the victim emerged. Fourth, the victim was found slumped on the ground with a fatal gunshot wound. Fifth, both petitioners were seen holding firearms near the crime scene. Sixth, the petitioners were inexplicably holding firearms. Seventh, they were the only individuals seen at the scene. These pieces of evidence, taken together, created a compelling inference that the Barbosas were responsible for the crime. The Court stated:

    There are several pieces of circumstantial evidence in this case that form an unbroken chain leading to a fair and logical conclusion that petitioners committed the crime of homicide.

    Moreover, the Supreme Court affirmed the lower courts’ finding of conspiracy between Roble and Ramdy Barbosa. The Court explained that conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. The evidence showed that the Barbosas, father and son, were both armed and confronted the victim together. The Court inferred that they acted in unison with the common objective of killing Artemio Betita, Jr. The Court noted their coordinated actions:

    They clearly acted in unison to achieve the common objective of killing the victim.

    The defense challenged the reliability of the witness testimony. However, the Court gave credence to the witness’s account, noting the absence of any improper motive. The Court has consistently held that the testimony of a witness should be given full faith and credence, especially when there is no showing of ill motive. In this case, the positive identification of the Barbosas as the persons last seen with the victim, combined with the circumstantial evidence, sufficiently established their guilt.

    Building on this principle, the Supreme Court addressed the issue of damages. While affirming the conviction, the Court modified the award of damages. It deleted the award of actual damages due to lack of supporting receipts, replacing it with temperate damages of P50,000.00. The Court also deleted the awards for attorney’s fees and litigation expenses, noting that these are generally not recoverable in criminal actions unless a separate civil action is filed or exemplary damages are awarded. The Court upheld the award of civil indemnity and added an award of moral damages, both in the amount of P50,000.00, in line with prevailing jurisprudence. Furthermore, the Court imposed an interest rate of 6% per annum on all damages from the date of finality of the Resolution until fully paid.

    FAQs

    What was the key issue in this case? The key issue was whether the circumstantial evidence presented by the prosecution was sufficient to prove the guilt of the accused beyond reasonable doubt for the crime of homicide.
    What is circumstantial evidence? Circumstantial evidence is indirect evidence that proves a fact in issue through inference from other proven facts. It requires the establishment of a series of facts that, when taken together, lead to a reasonable and logical conclusion about the matter in dispute.
    What are the requisites for circumstantial evidence to be sufficient for conviction? The requisites are: (1) there is more than one circumstance; (2) the facts from which the inferences are derived are proven; and (3) the combination of all circumstances is such as to produce a conviction beyond reasonable doubt.
    What is conspiracy in law? Conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. It requires a common design or purpose to commit the crime.
    What is the difference between actual and temperate damages? Actual damages are compensation for pecuniary loss that must be proven with reasonable certainty, usually through receipts and other evidence. Temperate damages are awarded when some pecuniary loss has been suffered but the amount cannot be proven with certainty.
    Why were the awards for attorney’s fees and litigation expenses deleted in this case? The awards were deleted because attorney’s fees and litigation expenses are generally not recoverable in criminal actions unless a separate civil action is filed or exemplary damages are awarded, neither of which applied in this case.
    What are moral damages? Moral damages are compensation for mental anguish, serious anxiety, wounded feelings, moral shock, social humiliation, and similar injury. They are awarded to compensate for the emotional suffering caused by the wrongful act.
    What is civil indemnity? Civil indemnity is a form of damages awarded automatically to the victim (or the victim’s heirs) in criminal cases, without the need for proof of actual damages. It is intended to compensate for the fact that a crime has been committed.

    This case illustrates the crucial role of circumstantial evidence in criminal proceedings, especially when direct evidence is lacking. The Supreme Court’s decision underscores the importance of establishing a clear and logical connection between the accused’s actions and the crime through a series of proven facts. The careful consideration of evidence, coupled with the application of relevant legal principles, ensures that justice is served, even in the absence of eyewitness testimony.

    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: Roble Barbosa and Ramdy Barbosa, Petitioners, vs. People of the Philippines, Respondent., G.R. No. 207193, July 24, 2017

  • Treachery and the Sanctity of the Home: Defining Murder in Philippine Law

    In People v. Kalipayan, the Supreme Court affirmed the conviction for murder, emphasizing the presence of treachery and the aggravating circumstance of dwelling. This means that an unexpected attack that ensures the victim cannot defend themselves, especially within their own home, elevates the crime from homicide to murder. This ruling underscores the judiciary’s commitment to protecting individuals within the sanctity of their residences, while providing clarity to the elements constituting murder under Philippine law.

    A Fatal Confrontation: When Does a Domestic Dispute Become Murder?

    Arnel Kalipayan was accused of murdering his former live-in partner, Glaiza Molina. The prosecution argued that Kalipayan entered Molina’s home unexpectedly and stabbed her multiple times, resulting in her death. Kalipayan admitted to the act but claimed the killing occurred during a heated argument, suggesting the absence of qualifying circumstances like treachery, evident premeditation, or abuse of superior strength. The central legal question was whether the prosecution sufficiently proved any qualifying circumstance to elevate the crime to murder, rather than simple homicide.

    The Regional Trial Court (RTC) initially found Kalipayan guilty of murder, focusing on the treachery involved in the sudden attack. The Court of Appeals (CA) affirmed this decision. The Supreme Court, in its review, delved into the specifics of the crime. It looked at whether the elements of murder were proven beyond reasonable doubt. The court scrutinized the presence of evident premeditation and treachery, ultimately siding with the prosecution’s version of events.

    The Court acknowledged that evident premeditation wasn’t sufficiently proven, clarifying that while Kalipayan may have intended to confront Molina, there wasn’t enough evidence to suggest a sustained plan to kill her. However, the Court firmly established the presence of treachery. According to jurisprudence, treachery exists when the offender employs means of execution that gives the person attacked no opportunity to defend themselves or retaliate, and such means are deliberately or consciously adopted. In this case, the sudden and unexpected nature of the attack, coupled with the fact that Molina was stabbed in the back while preparing dinner, proved that Kalipayan ensured that she could not defend herself.

    Key to the Court’s finding was the testimony of witnesses who described how Kalipayan entered Molina’s home and immediately launched the attack. The Medico-Legal Autopsy Report also supported the claim that Molina sustained posterior wounds, indicating that the initial attack was from behind. Building on this principle, the Supreme Court quoted the testimony of Josephine, Molina’s mother:

    Q: Upon entering your house, what if any did Arnel Kalipayan do?
    A: He suddenly entered the house without permission and approached my daughter who was at that time preparing for our meals stabbed her at her back and held her hair and let my daughter faced him and stabbed her on her stomach and the food that she ate spilled out of her stomach.

    This testimony, along with Celestina’s account, painted a picture of a swift and unprovoked assault, which aligned with the legal definition of treachery. The Court emphasized that the essence of treachery is the sudden and unexpected attack without the slightest provocation on the part of the person being attacked. Thus, the Court determined that all the elements of treachery were present, qualifying the crime as murder.

    Furthermore, the Court addressed the aggravating circumstance of dwelling. It emphasized that for dwelling to be considered, the crime must have been committed in the residence of the offended party and the latter did not give any provocation. Even though the RTC had dismissed this circumstance, the Supreme Court ruled that dwelling was indeed an aggravating factor in this case. The Court stated:

    [O]ne who goes to another’s house to hurt him or do him wrong is more guilty than he who offends him elsewhere.

    The fact that Molina was attacked in her own home, while engaged in a routine activity, without any provocation, demonstrated a disregard for the sanctity of the dwelling, thereby aggravating the crime. Given the presence of treachery and the aggravating circumstance of dwelling, the Supreme Court modified the penalty and damages awarded. The Court referenced People v. Jugueta to reassess the amounts that should be awarded to the victims of certain crimes. The original penalty was modified to reclusion perpetua, without eligibility for parole, in accordance with Republic Act No. 9346, which prohibits the imposition of the death penalty. The civil indemnity, moral damages, and exemplary damages were each increased to P100,000.00.

    The final ruling underscored the Court’s commitment to upholding the law and protecting individuals within their homes. The case serves as a reminder of the severe consequences for those who commit acts of violence under treacherous circumstances, particularly within the sanctuary of one’s dwelling.

    FAQs

    What was the key issue in this case? The central issue was whether the prosecution successfully proved any qualifying circumstance, like treachery, to elevate the crime from homicide to murder, considering the accused admitted to the killing.
    What is treachery in the context of murder? Treachery exists when the offender employs means of execution that gives the person attacked no opportunity to defend themselves or retaliate, and such means are deliberately or consciously adopted.
    What is the significance of the “dwelling” circumstance? The “dwelling” circumstance aggravates the crime because it was committed in the residence of the offended party, who did not provoke the attack, showing disrespect for the sanctity of the home.
    Why was the crime considered murder instead of homicide? The crime was considered murder due to the presence of treachery, as the attack was sudden, unexpected, and ensured the victim had no opportunity to defend herself.
    What penalties were imposed on the accused? The accused was sentenced to reclusion perpetua without eligibility for parole, along with the payment of civil indemnity, moral damages, and exemplary damages.
    How did the Supreme Court modify the damages awarded? The Supreme Court increased the civil indemnity, moral damages, and exemplary damages to P100,000.00 each, referencing the guidelines in People v. Jugueta.
    What is the impact of Republic Act No. 9346 on this case? Republic Act No. 9346 prohibits the imposition of the death penalty, resulting in the accused receiving a sentence of reclusion perpetua instead.
    Was evident premeditation proven in this case? No, the Court found that while the accused may have planned to confront the victim, there was insufficient evidence to prove a sustained plan to kill her, thus evident premeditation was not established.

    In conclusion, the Supreme Court’s decision in People v. Kalipayan reinforces the importance of proving qualifying circumstances beyond a reasonable doubt in murder cases. It illustrates how treachery and the sanctity of the home play critical roles in determining the severity of the crime and the corresponding penalties. This case offers valuable insights into the elements of murder under Philippine law, with particular emphasis on treachery and dwelling.

    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. Kalipayan, G.R. No. 229829, January 22, 2018

  • The High Cost of a Ride: Defining the Elements of Carnapping with Homicide

    In People v. Jeffrey Macaranas, the Supreme Court affirmed the conviction of the accused for carnapping with homicide, emphasizing that when a carnapping results in the death of the victim, the crime is qualified to reclusion perpetua. The ruling underscores the state’s commitment to prosecuting individuals who commit violence during vehicle theft, ensuring justice for victims and their families. This decision serves as a deterrent, reinforcing that the consequences for such actions extend far beyond the loss of property.

    From Guard to Guilty: When Does Being a Lookout Become Carnapping with Homicide?

    The case revolves around an incident on February 18, 2007, when Frank Karim Langaman and his girlfriend, Kathlyn Irish Mae Cervantes, were approached by three men while on Frank’s motorcycle. One of the men shot Frank, and another stole the motorcycle, while the third, Jeffrey Macaranas, acted as a lookout. Frank later died from his injuries, leading to charges of carnapping with homicide against Macaranas. The legal question at the heart of the case is whether Macaranas, as an accomplice, could be held equally responsible for the crime of carnapping with homicide, and what elements needed to be proven to secure a conviction.

    The Supreme Court anchored its analysis on Republic Act No. 6539, also known as the Anti-Carnapping Act of 1972, as amended. This law defines carnapping as the taking of a motor vehicle belonging to another without the owner’s consent, with intent to gain, or by means of violence or intimidation. Section 14 of the Act specifies penalties, escalating to reclusion perpetua to death when the owner, driver, or occupant is killed during the carnapping. Key to this case is the interpretation of the phrase “in the course of the commission of the carnapping or on the occasion thereof,” which determines when a killing elevates the crime to a special complex offense.

    SEC. 14. Penalty for Carnapping. Any person who is found guilty of carnapping, as this term is defined in Section two of this Act, shall, irrespective of the value of the motor vehicle taken, be punished by imprisonment for not less than fourteen years and eight months and not more than seventeen years and four months, when the carnapping is committed without violence or intimidation of persons, or force upon things; and by imprisonment for not less than seventeen years and four months and not more than thirty years, when the carnapping is committed by means of violence or intimidation of any person, or force upon things; and the penalty of reclusion perpetua to death shall be imposed when the owner, driver or occupant of the carnapped motor vehicle is killed or raped in the course of the commission of the carnapping or on the occasion thereof.

    The Court emphasized that to convict someone of carnapping with homicide, the prosecution must prove the essential elements of carnapping and the homicide itself. Moreover, the prosecution must demonstrate that the original intent was carnapping and that the killing occurred during or because of the carnapping. This distinction is crucial, as without proving the elements of carnapping, the homicide would be prosecuted separately under the Revised Penal Code.

    In this case, the prosecution successfully established all the necessary elements. Evidence showed that the vehicle was taken without the owner’s consent, through violence and intimidation, and with intent to gain. Kathlyn’s testimony placed Macaranas at the scene, acting as a lookout while his companions carried out the crime. Kathlyn positively identified Macaranas, and the court found her testimony credible, noting the absence of any ill motive on her part. The court also underscored the principle that it gives “the highest respect to the RTC’s evaluation of the testimony of the witness[es], considering its unique position in directly observing the demeanor of a witness on the stand.”

    The court addressed the defense’s argument that Kathlyn’s testimony was inconsistent and improbable, reiterating that inconsistencies do not necessarily discredit a witness, especially when the core testimony remains consistent and credible. It also found that the defense of denial and alibi was weak, particularly in the face of positive identification by the witness. Moreover, the defense failed to prove that it was physically impossible for Macaranas to be at the crime scene at the time of the incident.

    Furthermore, the Court considered the element of conspiracy, finding that Macaranas acted in concert with the other perpetrators. Conspiracy, the Court explained, does not always require direct evidence and can be inferred from the actions of the accused before, during, and after the crime. Macaranas’s role as a lookout, combined with the coordinated actions of the group, indicated a shared purpose and intent to commit the crime.

    Building on this principle, the Court then discussed the penalties associated with the crime. Because the carnapping resulted in the victim’s death, the penalty was appropriately set at reclusion perpetua. The Court also modified the monetary awards, increasing the amounts for civil indemnity, moral damages, and exemplary damages, aligning them with current jurisprudence for special complex crimes. This enhancement underscored the grave nature of the offense and the need for just compensation to the victim’s family.

    The decision in People v. Macaranas reinforces the principle that all participants in a crime, including those acting as lookouts or accomplices, can be held liable for the full consequences of their actions. The case serves as a reminder of the severe penalties associated with carnapping, especially when it results in violence or death. It underscores the judiciary’s commitment to protecting citizens from vehicle theft and related violence. This ruling also clarifies the standard of evidence required to prove carnapping with homicide, emphasizing the importance of establishing both the elements of carnapping and the causal link between the crime and the victim’s death.

    FAQs

    What is carnapping under Philippine law? Carnapping is the act of taking a motor vehicle belonging to another without the owner’s consent, with intent to gain, or through violence or intimidation. It is defined under Republic Act No. 6539, also known as the Anti-Carnapping Act of 1972, as amended.
    What is the penalty for carnapping with homicide? When the owner, driver, or occupant of the carnapped vehicle is killed during the commission of the carnapping, the penalty is reclusion perpetua to death. The killing elevates the crime to a special complex offense with severe consequences.
    What must the prosecution prove in a carnapping with homicide case? The prosecution must prove the elements of carnapping (taking, ownership, lack of consent, intent to gain) and the fact of the homicide. Critically, they must also show that the carnapping was the original intent and that the killing occurred during or because of the carnapping.
    What is the role of conspiracy in carnapping cases? Conspiracy exists when two or more persons agree to commit a crime and decide to execute it. In carnapping, if conspiracy is proven, each conspirator is held equally liable for the actions of the others, even if they did not directly participate in every aspect of the crime.
    How does the court assess the credibility of witnesses in carnapping cases? The court gives great weight to the trial court’s assessment of witness credibility, as the trial court directly observes the witness’s demeanor. Positive identification by a credible witness, absent any ill motive, is considered strong evidence.
    What is the significance of the phrase “in the course of the commission of the carnapping or on the occasion thereof”? This phrase determines when a killing elevates the crime to carnapping with homicide. It requires a close connection between the carnapping and the killing, indicating that the homicide occurred as a direct result of or during the carnapping.
    Can someone be convicted of carnapping with homicide if they only acted as a lookout? Yes, if conspiracy is proven, even those who acted as lookouts or accomplices can be convicted of carnapping with homicide. The key is demonstrating that they shared a common criminal intent and participated in the execution of the crime.
    What is the difference between actual damages and temperate damages? Actual damages are compensation for proven losses and expenses. When actual damages cannot be precisely determined, temperate damages may be awarded as a reasonable estimate of the loss suffered.

    In conclusion, People v. Jeffrey Macaranas provides a clear framework for understanding the elements and penalties associated with carnapping with homicide in the Philippines. It emphasizes the importance of proving intent, conspiracy, and the causal link between the carnapping and the victim’s death. The decision serves as a reminder of the serious consequences of engaging in violent vehicle theft and the judiciary’s commitment to delivering justice in such cases.

    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 of the Philippines v. Jeffrey Macaranas y Fernandez, G.R. No. 226846, June 21, 2017

  • Self-Defense Claims and the Limits of Justification: Understanding the Panerio Case

    In People v. Yolando B. Panerio, the Supreme Court clarified the application of self-defense in homicide cases, emphasizing the necessity of proving unlawful aggression, reasonable means of defense, and lack of provocation. The Court reduced the conviction from murder to homicide, underscoring that treachery must be proven beyond reasonable doubt and cannot be presumed. This decision reinforces the stringent requirements for valid self-defense claims and highlights the importance of clear evidence in establishing aggravating circumstances in criminal cases.

    From Billiard Brawl to Fatal Stabbing: Did Self-Defense Hold Up?

    The case revolves around the events of February 18, 1991, in Davao City, when Yolando Panerio and Alex Orteza were accused of murdering Elesio Ung. The prosecution’s case rested on the testimonies of several witnesses, including Virgilio Olivar, who recounted that Panerio and Orteza, while intoxicated, disrupted billiard games before encountering and stabbing Elesio. Following the stabbing, Panerio and Orteza approached Exipher C. Rebosura, a security guard, claiming that an unknown person had been stabbed. This led to their referral to the police, where Alojado, a police officer, discovered bloodstains on their hands and recovered a fan knife from Panerio and an ice pick from Orteza. The post-mortem examination revealed that Elesio suffered eleven stab and puncture wounds, leading to his death.

    In contrast, Panerio claimed self-defense, stating that Elesio initiated the aggression by boxing and attempting to stab him after Panerio refused a drink. Panerio testified that he managed to disarm Elesio and then stabbed him in defense. The Regional Trial Court (RTC) found Panerio and Orteza guilty of murder, a decision affirmed with modifications by the Court of Appeals (CA). The CA highlighted that the sheer number, nature, and location of the stab wounds refuted Panerio’s self-defense claim and appreciated the presence of treachery. Panerio appealed, arguing that the lower courts erred in not appreciating self-defense.

    The Supreme Court, in its analysis, reiterated that invoking self-defense implies an admission of responsibility for the act but claims justification. The burden of proof rests on the accused to demonstrate the elements of self-defense clearly and convincingly. These elements include unlawful aggression, reasonable necessity of the means used to prevent or repel the aggression, and lack of sufficient provocation. The Court stressed that unlawful aggression is the most critical element; without it, self-defense cannot be legally justified. Unlawful aggression must be real and imminent, posing an actual threat to one’s life or safety.

    The Court found Panerio’s testimony unconvincing and inconsistent with the evidence. Specifically, the number of stab wounds inflicted on Elesio contradicted a defensive response, indicating instead a determined effort to kill. Furthermore, the eyewitness account and the post-mortem findings undermined Panerio’s claim that Elesio initiated the attack. The principle that the means of defense must be reasonable in relation to the aggression was also central to the Court’s decision. The excessive number and severity of the wounds indicated that Panerio’s actions went beyond what was necessary for self-preservation. The court cited People v. More, 378 Phil. 1153, 1161 (1999), stating that “the presence of multiple stab wounds on the victim strongly indicates a determined effort to kill the victim.”

    Building on this principle, the Court addressed whether the crime should be qualified as murder. Treachery, as defined, involves employing means to ensure the execution of a crime against a person without risk to the offender from the defense the offended party might make. Two conditions must be met for treachery to be appreciated: the employment of means of execution that gives the person attacked no opportunity to defend himself or retaliate, and the deliberate or conscious adoption of such means. The Court emphasized that treachery must be proven by clear and convincing evidence and cannot be presumed. Here, the sole eyewitness, Olivar, only saw the stabbing in progress, providing no insight into how the attack began, thus precluding a finding of treachery.

    In its ruling, the Supreme Court modified the conviction from murder to homicide. The absence of treachery or any other qualifying circumstance meant that the crime fell under Article 249 of the Revised Penal Code (RPC), which defines and penalizes homicide. Article 249 states, “Any person who, not falling within the provisions of Article 246, shall kill another without the attendance of any of the circumstances enumerated in Article 248, shall be deemed guilty of homicide and be punished by reclusion temporal.” As such, the penalty was adjusted to an indeterminate sentence ranging from twelve years of prision mayor to seventeen years and four months of reclusion temporal.

    The Court also addressed the monetary awards to be paid to the heirs of Elesio Ung. Citing People v. Jugueta, G.R. No. 202124, 05 April 2016, 788 SCRA 331, the Court affirmed the award of P50,000.00 as civil indemnity and P50,000.00 as moral damages. However, it deleted the awards for exemplary and temperate damages, noting the absence of any aggravating circumstances. Additionally, all monetary awards were subjected to an interest rate of six percent (6%) per annum from the finality of the decision until fully paid, following the guidelines set forth in People v. Combate, 653 Phil. 487, 518 (2010).

    FAQs

    What was the key issue in this case? The key issue was whether the accused-appellant could validly claim self-defense and whether the crime committed was murder or homicide. The Supreme Court ultimately reduced the conviction to homicide due to the lack of proven treachery.
    What are the elements of self-defense? The elements of self-defense are unlawful aggression on the part of the victim, reasonable necessity of the means used to prevent or repel the aggression, and lack of sufficient provocation on the part of the person defending himself. All three elements must be proven to successfully claim self-defense.
    What is unlawful aggression? Unlawful aggression is an actual, sudden, and unexpected attack or imminent threat thereof, which puts the defendant’s life or limb in real danger. It is the most important element of self-defense.
    What is treachery? Treachery is the deliberate employment of means, methods, or forms in the execution of a crime that ensures its commission without risk to the offender from the defense the offended party might make. It must be proven as conclusively as the killing itself.
    Why was the conviction reduced from murder to homicide? The conviction was reduced because the prosecution failed to prove the existence of treachery, which is a qualifying circumstance for murder. Without treachery or any other qualifying circumstance, the crime is homicide.
    What is the penalty for homicide under the Revised Penal Code? Under Article 249 of the Revised Penal Code, the penalty for homicide is reclusion temporal, which ranges from twelve years and one day to twenty years. The specific sentence depends on the presence of any mitigating or aggravating circumstances.
    What damages were awarded in this case? The Supreme Court awarded P50,000.00 as civil indemnity and P50,000.00 as moral damages to the heirs of the deceased. It deleted the awards for exemplary and temperate damages due to the absence of aggravating circumstances.
    What is the significance of the Jugueta ruling cited in this case? The Jugueta ruling (G.R. No. 202124, 05 April 2016, 788 SCRA 331) provides a summary of the amounts of damages that may be awarded for different crimes, including homicide. It serves as a guide for determining appropriate compensation for victims and their families.

    The Supreme Court’s decision in People v. Yolando B. Panerio serves as a crucial reminder of the stringent requirements for claiming self-defense and the necessity of proving aggravating circumstances beyond reasonable doubt. The reduction of the conviction from murder to homicide underscores the importance of precise evidence and the proper application of legal principles in criminal cases.

    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 of the Philippines, Plaintiff-Appellee, v. Yolando B. Panerio alias John “Yolly” Labor and Alex (Jojo) F. Orteza, Accused, Yolando B. Panerio, Accused-Appellant., G.R. No. 205440, January 15, 2018

  • Competency of Child Witnesses: Overcoming Cerebral Palsy in Rape and Homicide Cases

    In People v. Golidan, the Supreme Court affirmed the conviction of appellants for rape with homicide, murder, and frustrated murder, emphasizing the competency of a child witness with cerebral palsy. The Court highlighted that a child’s physical condition does not automatically disqualify them from testifying, provided they can perceive and communicate their perceptions accurately. This ruling reinforces the importance of considering individual capabilities rather than relying on presumptions about disability, ensuring that justice is accessible to all victims, regardless of their physical or mental condition.

    Silent Voices, Unheard Truths: How a Child’s Testimony Unveiled a Brutal Crime

    The case revolves around the gruesome events of January 20, 1995, in Baguio City, where AAA, a babysitter, was raped and murdered, and a one-year-old baby, BBB, was murdered, and a ten-year-old girl, CCC, was the victim of frustrated murder. The key witness was CCC, who had cerebral palsy. The central legal issue was whether CCC’s testimony was admissible and credible, given her physical and communicative limitations. The prosecution presented CCC’s testimony, along with medical evidence and eyewitness accounts, to establish the guilt of Eduardo Golidan, Francis Nacionales, and Teddy Ogsila. The defense argued that CCC was not a competent witness due to her condition, and that their alibis proved they could not have committed the crimes.

    The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt, a decision that was later affirmed with modifications by the Court of Appeals (CA). The CA emphasized that any child can be a competent witness if they can perceive, and perceiving, can make known their perception to others and of relating truthfully facts respecting which they are examined. This principle is crucial in safeguarding the rights of vulnerable victims who may have unique challenges in communicating their experiences. Central to this case is the principle of **witness competency**, as enshrined in the Rules of Court. The rules state that a person is competent to testify if they can perceive and make known their perceptions.

    Building on this principle, the Supreme Court (SC) upheld the CA’s decision, reinforcing the idea that a witness’s physical or mental condition does not automatically disqualify their testimony. The SC noted that the trial court is in the best position to assess a witness’s competency, especially when expert testimony is presented to clarify the witness’s capabilities. The Court referenced the testimony of Dr. Divina Hernandez, who stated that despite Cherry Mae’s cerebral palsy, she could still perceive and recall events. This expert testimony was crucial in establishing CCC’s competency as a witness, as it demonstrated her ability to accurately recall and communicate her experiences.

    Regarding the defense’s argument that CCC’s initial failure to identify the accused undermined her credibility, the SC sided with the CA, noting that CCC was recovering from severe trauma and physical injuries at the time. The Court recognized that the shock and fear experienced by CCC could have temporarily affected her ability to identify the perpetrators. This recognition aligns with the principles of **child witness examination**, which emphasizes the need for sensitivity and flexibility when dealing with child witnesses who have experienced trauma. The Court has consistently held that failure to immediately identify the perpetrator does not necessarily impair a witness’s credibility, especially in cases involving traumatic events.

    The Supreme Court also affirmed the finding of conspiracy among the accused. The prosecution successfully demonstrated that the accused acted in concert with a common unlawful purpose. The Court highlighted that conspiracy need not be proven by direct evidence, as it can be inferred from the acts of the accused in accomplishing a common unlawful design. The surviving victim testified regarding the specific acts perpetrated by the appellants against her and the other victims, which show a unity of purpose and sentiment, and a concerted effort on the part of the appellants to commit the gruesome crimes. The SC emphasized that the defense of denial and alibi, as presented by the accused, was weak compared to the positive identification made by Cherry Mae.

    Furthermore, the Court addressed the issue of alibi, reinforcing the principle that for alibi to prosper, the accused must prove that they were elsewhere when the crime was committed and that it was physically impossible for them to be at the crime scene. The SC found that the accused failed to provide sufficient evidence to support their alibis, particularly given the testimonies placing them in the vicinity of the crime scene. The Court then modified the monetary awards, increasing the amounts to reflect current jurisprudence and to express society’s outrage over such heinous crimes. The practical implications of this ruling are significant, as it ensures that individuals with disabilities are not automatically disqualified from participating in the legal process as witnesses.

    This case also highlights the importance of considering the **Rule on the Examination of a Child Witness**, which provides guidelines for creating a supportive environment for child witnesses and ensuring that their testimony is reliable. Although the Rule was not in effect at the time of the trial, the SC referenced its provisions to underscore the flexibility given to courts in examining child witnesses. Specifically, the Court noted that leading questions may be allowed if they further the interests of justice, and that the focus should be on facilitating the ascertainment of truth while minimizing trauma to the child.

    The decision aligns with the broader legal trend of recognizing the rights and capabilities of individuals with disabilities. By affirming the competency of CCC, the Supreme Court has sent a clear message that the legal system must adapt to accommodate the needs of all witnesses, regardless of their physical or mental condition. This case sets a precedent for future cases involving witnesses with disabilities, ensuring that their voices are heard and their testimony is given due weight. “That the witness is a child cannot be the sole reason for disqualification,” the Court noted, referencing People v. Esugon, reinforcing the shift away from dismissive treatment of child witnesses.

    In conclusion, People v. Golidan serves as a landmark decision in Philippine jurisprudence, emphasizing the importance of witness competency and the need for a flexible and inclusive legal system. The case reinforces the principle that every individual, regardless of their physical or mental condition, has the right to participate in the legal process and to have their testimony considered fairly. This case is a reminder that justice must be accessible to all, and that the legal system must be vigilant in protecting the rights of vulnerable individuals.

    FAQs

    What was the key issue in this case? The key issue was whether a child witness with cerebral palsy could be deemed competent to testify in court, given her physical and communicative limitations.
    What crimes were the accused convicted of? The accused were convicted of rape with homicide, murder, and frustrated murder, stemming from the events that occurred on January 20, 1995.
    What was the role of Cherry Mae Bantiway in the case? Cherry Mae Bantiway, a child with cerebral palsy, was the lone survivor and primary witness to the crimes, providing crucial testimony that identified the accused.
    How did the Court determine Cherry Mae’s competency as a witness? The Court relied on expert testimony from medical professionals who confirmed that despite her cerebral palsy, Cherry Mae could perceive, recall, and communicate events accurately.
    What is the significance of the "Rule on the Examination of a Child Witness" in this context? The Rule provides guidelines for creating a supportive environment for child witnesses and allows flexibility in questioning to ensure reliable testimony while minimizing trauma.
    Why did the Court uphold the finding of conspiracy among the accused? The Court found that the accused acted in concert with a common unlawful purpose, as evidenced by their coordinated actions and the surviving victim’s testimony.
    How did the Court address the alibis presented by the accused? The Court found the alibis insufficient, as the accused failed to prove it was physically impossible for them to be at the crime scene and there was positive identification from the witness.
    What was the final decision of the Supreme Court in this case? The Supreme Court affirmed the Court of Appeals’ decision, upholding the conviction of the accused and modifying the monetary awards to align with current jurisprudence.
    What legal principles were central to the Supreme Court’s decision? Central legal principles were the determination of witness competency, evaluation of child testimony, and finding of conspiracy, and the assessment of alibi defenses.

    This case underscores the judiciary’s commitment to upholding the rights of vulnerable witnesses and ensuring that justice is served, regardless of the challenges involved. The ruling in People v. Golidan serves as a guiding precedent for future cases involving witnesses with disabilities, promoting a more inclusive and equitable legal system.

    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 of the Philippines vs. Eduardo Golidan, G.R. No. 205307, January 11, 2018

  • Self-Defense vs. Unlawful Aggression: Establishing Guilt in Homicide Cases

    In a ruling concerning the case of People of the Philippines v. PFC Enrique Reyes, the Supreme Court clarified the critical elements of self-defense in homicide cases, emphasizing the necessity of proving unlawful aggression by the victim. The Court found Reyes guilty of murder, reversing the Court of Appeals’ decision, highlighting that his actions did not constitute self-defense due to the absence of unlawful aggression on the part of the deceased. This decision reinforces the principle that self-defense cannot be claimed unless there is an actual and imminent threat to one’s life, setting a stringent standard for its justification and affecting how similar cases will be approached in the future.

    From Barracks to Courtroom: When Does Protecting Yourself Become Murder?

    The case revolves around the death of Danilo Estrella, who was fatally shot by PFC Enrique Reyes. Reyes, initially charged with murder, claimed self-defense, asserting that Estrella was about to shoot him. The Regional Trial Court (RTC) convicted Reyes of murder, but the Court of Appeals (CA) modified the conviction to homicide, finding no sufficient evidence of treachery or evident premeditation. The Supreme Court then took on the case to determine whether Reyes acted in self-defense, which would absolve him of criminal responsibility, or if his actions constituted murder.

    By invoking self-defense, Reyes admitted to inflicting the injuries that caused Estrella’s death. This shifted the burden of proof to Reyes to demonstrate that his actions were justified under the law. To successfully claim self-defense, the accused must prove three elements: unlawful aggression on the part of the victim, reasonable necessity of the means employed to prevent or repel the aggression, and lack of sufficient provocation on the part of the person invoking self-defense. The absence of even one of these elements negates the claim of self-defense.

    The most critical element is unlawful aggression. As the Supreme Court stated:

    Unlawful aggression is the indispensable element of self-defense, for if no unlawful aggression attributed to the victim is established, self-defense is unavailing for there is nothing to repel. Verily, there can be no self-defense, whether complete or incomplete, unless the victim had committed unlawful aggression against the person invoking it as a justifying circumstance.

    Unlawful aggression must be an actual physical assault or an imminent threat of one. The threat must be real and immediate, not merely imagined. The Court outlined three conditions to establish unlawful aggression:

    1. There must be a physical or material attack or assault.
    2. The attack or assault must be actual, or at least imminent.
    3. The attack or assault must be unlawful.

    In Reyes’ case, the Court found the element of unlawful aggression to be missing. The evidence did not convincingly show that Estrella posed an imminent threat to Reyes’ life. Witnesses testified that Estrella was merely approaching Reyes with a gun, but there was no overt act of aggression. The Court referenced a previous ruling, People v. Rubiso, emphasizing that even drawing a weapon is insufficient to establish unlawful aggression unless there is a clear intent to cause harm.

    Assuming that Hubines had a gun and pulled it, however, records show that he did not manifest any aggressive act which may have imperiled the life and limb of herein appellant. It is axiomatic that the mere thrusting of one’s hand into his pocket as if for the purpose of drawing a weapon is not unlawful aggression. Even the cocking of a rifle without aiming the firearm at any particular target is not sufficient to conclude that one’s life was in imminent danger. Hence, a threat, even if made with a weapon, or the belief that a person was about to be attacked, is not sufficient. It is necessary that the intent be ostensibly revealed by an act of aggression or by some external acts showing the commencement of actual and material unlawful aggression.

    The prosecution’s witnesses also testified that Estrella was walking home when Reyes suddenly shot him, further undermining Reyes’ claim of self-defense. The testimonies of these witnesses were deemed credible by both the RTC and CA, and the Supreme Court found no reason to deviate from their findings.

    Reyes argued that a death threat from Estrella’s uncle, Manuel Sanchez, and overhearing Estrella’s plan to kill him, justified his actions. However, the Court found that these threats did not constitute imminent unlawful aggression. An attack must be at the point of happening and cannot be based on mere threats or imaginary dangers. The Court also noted that the alleged threat overheard by Reyes’ nephew did not specifically refer to Reyes.

    Furthermore, the nature and number of wounds inflicted on Estrella indicated an intent to kill rather than merely repel an attack. Estrella suffered multiple gunshot wounds, including fatal shots to the head and collarbone. These wounds refuted Reyes’ claim that he was only trying to defend himself. As the Court emphasized, physical evidence is paramount, and the severity of the wounds spoke against the claim of self-defense.

    The Court also found inconsistencies in Reyes’ account of the incident. His claim that he tried to lift Estrella to bring him to the hospital after shooting him, but was then fired upon by Estrella’s group, strained credulity. The Court found it implausible that Estrella’s group would wait until Reyes had fired several shots and attempted to lift Estrella before firing back.

    While the CA appreciated the mitigating circumstance of voluntary surrender based on the testimony of a police officer, the Supreme Court deemed it more accurately as analogous to voluntary surrender. Article 13 of the Revised Penal Code lists the following as mitigating circumstances:

    Article 13. Mitigating circumstances.- The following are mitigating circumstances:

    xxxx

    7. That the offender had voluntarily surrendered himself to a person in authority or his agents, or that he had voluntarily confessed his guilt before the court prior to the presentation of the evidence for the prosecution;

    xxxx

    10. And, finally, any other circumstances of a similar nature and analogous to those above mentioned.

    Because Reyes remained at his house knowing the police were coming and surrendered himself upon their arrival, this qualified as a mitigating circumstance similar to voluntary surrender. The Court then determined the appropriate penalty for murder, considering this mitigating circumstance.

    The Supreme Court ultimately modified the CA’s decision, finding Reyes guilty of murder due to the presence of treachery. Treachery exists when the offender employs means to ensure the execution of the crime without risk to themselves. The prosecution’s witnesses credibly testified that Reyes suddenly shot Estrella, who was walking towards his house, without giving him a chance to defend himself. The Court ruled that treachery may still be appreciated even if the victim was forewarned if the execution of the attack made it impossible for the victim to retaliate or defend himself.

    Having found Reyes guilty of murder, the Court then determined the appropriate sentence and damages, keeping with prevailing jurisprudence. The Court increased the civil indemnity and moral damages to P100,000.00 each and awarded exemplary damages of P100,000.00. Additionally, Reyes was ordered to pay temperate damages of P50,000.00. All monetary awards were made subject to interest at the rate of six percent (6%) per annum from the finality of the decision until fully paid.

    FAQs

    What was the key issue in this case? The key issue was whether PFC Enrique Reyes acted in self-defense when he shot and killed Danilo Estrella, or whether his actions constituted murder. The Supreme Court examined the elements of self-defense, particularly the requirement of unlawful aggression.
    What is unlawful aggression? Unlawful aggression is an actual physical assault or an imminent threat of such assault. It must be an immediate and real danger to one’s life or personal safety, not merely a perceived or imagined threat.
    What are the elements of self-defense? The elements of self-defense are: (1) unlawful aggression on the part of the victim; (2) reasonable necessity of the means employed to prevent or repel the aggression; and (3) lack of sufficient provocation on the part of the person invoking self-defense. All three elements must be present to successfully claim self-defense.
    Why did the Supreme Court find Reyes guilty of murder? The Supreme Court found Reyes guilty of murder because he failed to prove unlawful aggression on the part of Estrella. The evidence showed that Estrella was walking home and did not pose an imminent threat to Reyes when he was shot.
    What is the significance of treachery in this case? Treachery is a qualifying circumstance that elevates homicide to murder. The Supreme Court found that Reyes employed treachery by suddenly attacking Estrella, giving him no chance to defend himself.
    What mitigating circumstance was considered in this case? The Court considered a mitigating circumstance analogous to voluntary surrender. Reyes remained at his house knowing the police were coming and surrendered himself to them upon their arrival.
    What damages were awarded in this case? The Supreme Court awarded civil indemnity, moral damages, and exemplary damages of P100,000.00 each, as well as temperate damages of P50,000.00. All monetary awards were subject to interest at the rate of six percent (6%) per annum from the finality of the decision until fully paid.
    How does this case affect future self-defense claims? This case reinforces the stringent standard for claiming self-defense, particularly the necessity of proving unlawful aggression. It emphasizes that a mere threat or belief of an impending attack is not sufficient; there must be an actual or imminent physical assault.

    The Supreme Court’s decision in People v. Reyes underscores the importance of proving imminent danger in self-defense claims. This ruling serves as a stark reminder that claiming self-defense requires concrete evidence of unlawful aggression and that the response must be proportionate to the threat. The strict interpretation of self-defense ensures accountability and protects individuals from unjustified violence.

    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 OF THE PHILIPPINES, PLAINTIFF-APPELLEE, v. PFC ENRIQUE REYES, ACCUSED-APPELLANT., G.R. No. 224498, January 11, 2018

  • Reversal of Conviction: Distinguishing Homicide from Murder and Attempted Kidnapping

    The Supreme Court reversed the lower courts’ decision, finding Eugene Villanueva guilty only of homicide, not attempted kidnapping with murder. The prosecution failed to prove the elements of kidnapping, and treachery was not established to qualify the killing as murder. This means Villanueva faces a lesser penalty, highlighting the importance of proving each element of a crime beyond a reasonable doubt and distinguishing between the different classifications of criminal offenses like homicide versus murder.

    From Kidnapping Plot to Unintentional Killing: When Intent Determines the Crime

    This case revolves around the tragic death of Reggie Pacil and the subsequent conviction of Eugene Villanueva for attempted kidnapping with murder. The initial plan, according to the prosecution, was to kidnap Pacil’s Canadian friend, Ray Truck, for ransom. However, when Truck didn’t appear, the plan allegedly shifted to Pacil. The events that unfolded in a motel room led to Pacil’s death, but the Supreme Court questioned whether the evidence supported the charges of attempted kidnapping and murder.

    The Court delved into the elements of kidnapping, as defined under Article 267 of the Revised Penal Code (RPC), particularly whether the accused intended to deprive the victim of his liberty. The RPC states:

    Article 267. Kidnapping and serious illegal detention. – Any private individual who shall kidnap or detain another, or in any other manner deprive him of his liberty, shall suffer the penalty of reclusion perpetua to death:

    The decision hinged on the lack of concrete evidence showing that Villanueva and his cohorts intended to actually deprive the victim of his liberty. The court emphasized that intent is the essence of kidnapping, and this element was not sufficiently proven. The court noted the lack of motive to kidnap the victim, given the initial plan to target Truck. The acts of waiting for Pacil to fall asleep and tying him up were deemed insufficient to prove intent to detain him or deprive him of his liberty.

    Villanueva claimed self-defense, admitting his involvement in the killing but arguing he acted to protect himself. To justify self-defense, the accused must prove unlawful aggression on the part of the victim; the reasonable necessity of the means employed to prevent or repel it; and lack of sufficient provocation on the part of the accused. However, the courts found Villanueva’s account unconvincing, failing to establish unlawful aggression from the victim. The Court referenced People v. Del Castillo, 679 Phil. 233, 250 (2012), underscoring that unlawful aggression is a primordial element, and without it, self-defense is untenable.

    The Supreme Court also disagreed with the lower courts’ finding of treachery, which would have qualified the killing as murder. Treachery requires the employment of means, methods, or forms in the execution of the crime that directly and specially ensure its execution without risk to the offender. In People v. Garcia, 571 Phil. 483, 503 (2001), the Court emphasized that treachery involves a deliberate or conscious choice of the means of execution. The records lacked evidence that Villanueva and his co-accused planned to kill Pacil in a manner that would ensure the execution of the crime without any risk to themselves.

    However, the Court affirmed the presence of conspiracy among the accused. Conspiracy can be inferred from the actions of the accused before, during, and after the commission of the crime, suggesting a concerted effort and unity of purpose. Villanueva did not prevent Norada from striking Pacil, helped wrap the body, and disposed of it in a sugarcane field. These actions indicated a shared intent to commit the crime. Thus, applying the principle that “the act of one is the act of all,” Villanueva was deemed guilty as a co-conspirator and co-principal.

    With treachery and abuse of superior strength not proven, the crime was downgraded to homicide, punishable under Article 249 of the RPC with reclusion temporal. Given the absence of mitigating circumstances, the Court applied the Indeterminate Sentence Law, sentencing Villanueva to an indeterminate prison term of ten (10) years of prision mayor, as minimum, to seventeen (17) years and four (4) months of reclusion temporal, as maximum.

    Regarding civil liability, the Court adjusted the amounts to align with current jurisprudence. The civil indemnity was reduced from P75,000.00 to P50,000.00, and the exemplary damages were deleted. The amount of P50,000.00 as temperate damages was imposed in lieu of actual damages. The award of P1,950,967.26 for loss of earning capacity, initially granted by the RTC, was restored, calculated based on the victim’s net earning capacity using the formula: Net earning capacity = 2/3 x (80 – age) x (Gross Annual Income – Reasonable Living Expenses).

    FAQs

    What was the key issue in this case? The main issue was whether Eugene Villanueva was guilty of attempted kidnapping with murder, or only homicide. The Supreme Court ultimately found him guilty only of homicide.
    What is the definition of kidnapping under the Revised Penal Code? Kidnapping involves the unlawful taking and detention of a person, depriving them of their liberty. Essential elements include illegal detention and specific circumstances like length of detention or the victim’s status.
    What is treachery and how does it affect a murder charge? Treachery is a qualifying circumstance that elevates a killing to murder. It involves employing means to ensure the crime’s execution without risk to the offender, making it impossible for the victim to defend themselves.
    What is the legal definition of self-defense in the Philippines? Self-defense requires unlawful aggression by the victim, reasonable necessity of the defense, and lack of provocation by the accused. All three elements must be proven to successfully claim self-defense.
    How does conspiracy affect criminal liability? In conspiracy, the act of one conspirator is the act of all. Each conspirator is equally liable for the crime, regardless of their individual participation, because they share a common purpose.
    What is the difference between homicide and murder? Homicide is the killing of a person without any qualifying circumstances. Murder, on the other hand, is homicide qualified by circumstances like treachery, evident premeditation, or cruelty.
    What is the significance of proving intent in criminal cases? Intent is a crucial element in many crimes, including kidnapping. Proving intent demonstrates that the accused had the specific mental state required to commit the crime, influencing the charges and penalties.
    What is the Indeterminate Sentence Law? The Indeterminate Sentence Law requires courts to impose a minimum and maximum term of imprisonment. This allows for parole consideration, giving the offender an opportunity for rehabilitation.
    How is loss of earning capacity calculated in Philippine law? Loss of earning capacity is calculated based on the victim’s expected lifespan, gross annual income, and necessary living expenses. The formula considers the victim’s age and earning potential at the time of death.

    This case underscores the importance of meticulously proving each element of a crime and the distinctions between different classifications of offenses. While conspiracy was established, the failure to prove intent for kidnapping and the absence of treachery led to a conviction for the lesser crime of homicide.

    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 OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. EDILBERTO NORADA Y HARDER, AND AGUSTIN SEVA Y LACBANES, ACCUSED, EUGENE VILLANUEVA Y CAÑALES, ACCUSED-APPELLANT., G.R. No. 218958, December 13, 2017