Facts:

The case involves Cristito Austria y Rodis (the petitioner-appellant) versus the People of the Philippines and the Honorable Court of Appeals (respondents-appellees). The events unfolded on June 28, 1980, at approximately 7:00 PM inside the San Miguel Magnolia Poultry Farm compound located in Alfonso, Cavite. Austria was serving as the Officer-in-Charge of the security force at the facility when Roberto Miranda, a driver for the poultry and dairy farm, arrived in a company wagon. He was permitted entry by another security guard, Nemesio Matalog. Soon after entering, Austria and Miranda engaged in a physical altercation, exchanging fist blows in which they were separated by Matalog and a farm supervisor, Ronnie Japlo.

After being restrained, Matalog brought Austria back to the guardhouse, while Japlo took Miranda away. While Matalog was preoccupied, Austria retrieved a shotgun that was near the guardhouse and subsequently shot Miranda, resulting in Miranda’s death. Several witne

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Facts:

Background and Incident

• The accused, Cristito Austria, acted as Officer-in-Charge (OIC) of the security force at the San Miguel Magnolia Poultry and Dairy Farm in Alfonso, Cavite.
• On June 28, 1980, during his duty at the guardhouse (operating between 6:00 p.m. and 6:00 a.m.), Roberto Miranda, a driver employed by the company, arrived in a company wagon and entered the compound.
• At the gate, Nemesio Matalog, a security guard, permitted Miranda’s entry into the premises.

Sequence of Events and Confrontation

• After Miranda entered the compound, he and the accused were seen engaging in a physical altercation involving the exchange of fist blows.
• Both Nemesio Matalog and Ronnie Japlo, the farm supervisor, intervened to pacify and separate the parties.
• The accused was taken back to the guardhouse by Matalog, while Japlo helped escort Miranda away.
• While finalizing details (such as obtaining a trip ticket for Miranda), the accused allegedly took hold of his service shotgun and proceeded to approach Miranda.
• According to the prosecution’s witnesses, notably Japlo and Matalog, the accused fired the shotgun, fatally wounding Miranda, whose body was subsequently found approximately ten meters away from the guardhouse.

Evidence and Testimonies

• Multiple prosecution witnesses testified:
• Nemesio Matalog described the incident as a struggle for control of the firearm culminating in the accidental or intentional discharge.
• Ronnie Japlo corroborated the sequence, indicating that after separating the two men, he witnessed the accused retrieve the shotgun and then moving toward Miranda.
• A guard book report, handwritten by Matalog, recorded the unusual incident including the details of the struggle and the ensuing gun discharge.
• Testimony from other witnesses such as Policemen Silvino Avinante and Angel Lucero, and a medico-legal examination by Dr. Desiderio Moraleda, who identified gunshot wounds and lacerations on Miranda, supported the narrative of a fatal shooting.

Defendant’s Version and Defense Theory

• The accused contended that he did not intentionally shoot Miranda.
• His defense maintained that while he possessed a shotgun, the firearm accidentally discharged during a twenty-second grappling for its possession with Miranda.
• Additional evidence including a written statement by Matalog and testimony from other co-workers supported aspects of the accused’s story, even though it was characterized as self-serving.

Court Proceedings and Jurisdictional Issues

• Initially charged with murder, the accused was tried in the defunct Circuit Criminal Court of the Seventh Judicial District in Pasig, which later became the Regional Trial Court (RTC) due to judicial reorganization.
• After Judge Pena’s disability and subsequent death, and the reorganization of the courts (abolishing the Circuit Criminal Courts), questions emerged regarding whether jurisdiction should have transferred to the Cavite RTC—the venue where the crime was committed—or remained with the Pasig RTC.
• Despite the jurisdictional controversy, the accused actively pursued his case before the Pasig RTC, requesting a judgment of acquittal based on his defense.
• Ultimately, the accused was found guilty of homicide—not murder—with mitigating circumstances (voluntary surrender) applied to his sentence.

Trial Court and Appellate Considerations

• The trial court, after extensive evidence presentation and conflicting testimonies, convicted the accused of homicide and imposed an indeterminate sentence (ten years prision mayor minimum to twelve years and one day reclusion temporal maximum) along with monetary penalties.
• On appeal, the petitioner raised several assigned errors concerning the appreciation of evidence, evaluation of physical and testimonial evidence, and jurisdictional transfer issues.
• Key points of contention included:
• The distance of the victim’s body from the guardhouse and its implication on whether the shooting occurred accidentally or deliberately.
• Discrepancies between the guard book report entries and the courtroom testimonies of prosecution witnesses.
• The interpretation of the wound characteristics (contact fire versus near contact fire) and their consistency with an accidental discharge during a physical struggle.

Issue:

Jurisdictional Controversy

• Whether, upon abolishing the Circuit Criminal Courts and transferring jurisdiction, the case should have been moved from the Pasig RTC to the Cavite RTC, where the crime was committed.
• The implications of the accused’s active participation in proceedings before the Pasig RTC despite his contention regarding the proper venue.

Evaluation and Credibility of Evidence

• Whether the evidence, including the guard book report and the testimonies of prosecution witnesses (Nemesio Matalog and Ronnie Japlo), sufficiently established that the accused deliberately shot the victim.
• Whether the physical evidence (i.e., the position of the victim’s body and the nature of the wound) conclusively disproved the accused’s claim of accidental discharge during a struggle for the shotgun.

Appellate Errors and Abuse of Discretion

• Whether the Court of Appeals gravely abused its discretion in overruling evidence that could have created reasonable doubt regarding the accused’s guilt.
• Whether the inferences drawn by the appellate court from the evidence were speculative, contrary to the actual physical evidence and testimonies on record.

Impact of Inconsistencies and Recantations

• The effect of Matalog’s recanting testimony regarding the guard book entry on the overall credibility of the prosecution’s case.
• Whether the discrepancies between Matalog’s written report and his courtroom testimony warrant a reversal of the conviction due to reasonable doubt.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)