Case Digest (G.R. No. L-43527)
Facts:
Eliseo Araneta, Jr. v. Court of Appeals and People of the Philippines; Benjamin Bautista v. Court of Appeals and People of the Philippines, G.R. Nos. L-43527 and L-43745, July 03, 1990, Supreme Court First Division, Gancayco, J., writing for the Court.Petitioners are Eliseo Araneta, Jr. and Benjamin Bautista; respondents are the Court of Appeals and the People of the Philippines. An Information was filed on May 14, 1973 charging Araneta, Bautista, Eden Ng, and Joselito Santiago with murder for the death of Manuel Esteban, Jr. on March 23, 1972. After arraignment and trial, the Circuit Criminal Court of Manila (trial court) rendered judgment on August 30, 1973 finding Araneta and Bautista guilty as principals of homicide and acquitting Ng and Santiago. The trial court recognized voluntary surrender as mitigating and fixed civil indemnities and consequential damages; it also ordered confiscation of Araneta’s gun.
Both Araneta and Bautista appealed. On February 20, 1976 the Court of Appeals affirmed the conviction but modified the award for loss of earning capacity, reducing consequential damages. Separate petitions for review on certiorari by Araneta and Bautista were consolidated in this Court by resolution dated September 6, 1976.
The trial evidence, as found by both courts, showed that on or about midnight of March 22–23, 1972 the victim and companions were drinking at the Sands Kitchenette when a napkin container was thrown from petitioners’ group. A confrontation ensued, Bautista pushed the victim, and Araneta (left-handed; right hand atrophied) fired a shot hitting the victim in the back (wound No. 2). The victim then drew his gun and fired, wounding a companion of Araneta; during the ensuing scuffle Bautista held the victim and fired a shot to the chest (wound No. 1). The victim was brought to the hospital and pronounced dead on arrival.
Post-mortem findings by Dr. Abelardo B. Lucero reported two gunshot wounds: an anterior right chest contact wound (fatal, with internal lacerations) and a posterior left midlateral chest wound (superficial, slight). The expert opined the two wounds were caused by different firearms and that the posterior wound (wound No. 2) preceded the anterior contact wound (wound No. 1). The trial court attributed wound No. 2 to Araneta and wound No. 1 to Bautista.
Araneta contended he was at most guilty of slight physical injuries or should be acquitted by reason of self-defense or ...(Pro-only)
Issues:
- May this Court reassess or disturb the factual findings of the trial court and the Court of Appeals in this criminal case?
- Was Eliseo Araneta, Jr. entitled to justification by self-defense or defense of strangers?
- Is Araneta criminally liable for the homicide (death) of Manuel Esteban, Jr., or only for slight physical injuries (or attempted homicide) given the medical and ballistic findings and absence of conspiracy?
- Was Benjamin Bautista properly co...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)