G.R. No. 226656 - Gere vs. Anglo-Eastern Crew Management Phils., Inc.

Aron Anisco, the petitioner, and his brother Franklin Anisco were charged with homicide for the killing of Rolly D. Apinan.
The Information, dated March 8, 2002, alleged that on January 1, 2002, during a New Year celebration in Roxas City, the accused, acting in concert and without justifiable motive, attacked Rolly D. Apinan with a firearm which resulted in multiple gunshot and related wounds.
The criminal complaint detailed specific wounds on various parts of the victim’s body and charged that these wounds led to his death.

During the festivities at Sitio Luyo, Barangay Culasi, eyewitness accounts described the following:

Rolly was seen dancing on stage while his wife Merla and brother Roldan were nearby.
Aron, approaching the stage, greeted Rolly, after which Franklin pointed a gun at the victim.
Franklin stepped back and fired, hitting Rolly on the right chest, after which both Aron and Franklin fled with the firearm.

The prosecution called several key witnesses including Merla Apinan, Roldan Apinan, Dr. Ma. Esperanza Gepillano, SPO4 Crispin Azarcon, and SPO1 Cornelio Acielo.
Medical evidence, including the Post Mortem Examination Report by Dr. Gepillano, confirmed that Rolly’s death resulted from massive blood loss and shock due to a gunshot wound, with possibilities of cardiac tamponade or pneumoperitoneum.

During trial, both Aron and Franklin entered pleas of not guilty.
Aron’s defense argued self-defense, contending that during a struggle over a firearm, an accidental discharge occurred.
The prosecution, however, presented testimonies and physical evidence that strongly identified Aron as the shooter.
The Regional Trial Court (RTC) acquitted Franklin for lack of evidence but found Aron guilty beyond reasonable doubt of homicide under Article 249 of the Revised Penal Code (RPC).
The RTC ruled that Aron failed to demonstrate all the elements of self-defense—especially that he did not adopt reasonable measures to repel the alleged aggression.

Aron filed a motion for reconsideration which was denied by the RTC, leading to his appeal to the Court of Appeals (CA).
In its decision dated December 11, 2017, the CA affirmed with modification the RTC’s ruling:

Aron’s conviction for homicide was confirmed.
Modifications included revised monetary awards for actual damages, moral damages, exemplary damages, and civil indemnity.
The CA emphasized that Aron's claims of self-defense and accidental firing were not sufficiently proven.

Subsequently, Aron’s Motion for Reconsideration filed on February 2, 2018 was also denied by the CA in a resolution dated August 16, 2018.

Aron, unsatisfied with the appellate rulings, filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court before the Supreme Court.
His primary contentions were that:

The CA erred by affirming his conviction despite prosecution witnesses’ testimonies allegedly implicating Franklin.
The CA disregarded his defense of “accidental firing,” relying improperly on the precedent set in the Pomoy case.

The Supreme Court ultimately denied Aron’s petition, affirming that the evidence and legal reasoning were sufficient to sustain his conviction.

Whether the trial and appellate courts committed reversible errors by convicting Aron for homicide despite conflicting witness testimonies regarding which brother actually discharged the firearm.
Whether Aron’s defense of self-defense, including the claim of accidental firing, was adequately supported by evidence to exonerate him.
Whether the Court of Appeals erred in modifying the monetary awards (actual, moral, exemplary damages, and civil indemnity) in view of Aron’s defenses and the comparisons drawn with the Pomoy case.