Title
Del Rosario vs. People
Case
G.R. No. 141749
Decision Date
Apr 17, 2001
Florencio Del Rosario is sentenced to prison and ordered to pay death indemnity for homicide after inadequately establishing a claim of self-defense in the shooting of Remy Sinco.
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Case Digest (G.R. No. 141749)

Facts:

  • Petitioner: Florencio Del Rosario
  • Respondent: People of the Philippines
  • Incident Date: August 7, 1993
  • Location: Cabugao, Ilocos Sur
  • Charge: Murder for the killing of Remy Sinco
  • Information filed: November 8, 1993, alleging conspiracy to kill with treachery and evident premeditation
  • Prosecution witnesses included Lorna Sinco (victim's spouse) and police investigators
  • Testimony: Sinco was shot at point-blank range while being restrained by others
  • Defense: Claimed self-defense, asserting Sinco shot first
  • Trial Court Verdict: Del Rosario found guilty of homicide, acquitted co-accused due to lack of evidence of conspiracy
  • Sentence: Indeterminate penalty of six years and one day of prision mayor to twelve years and one day of reclusion temporal, plus P50,000 death indemnity to victim's heirs
  • Court of Appeals affirmed the decision on September 29, 1999
  • Del Rosario filed a petition for review on certiorari

Issue:

  • (Unlock)

Ruling:

  • The Court affirmed the Court of Appeals' decision, stating the petitioner failed to prove self-defense.
  • The Court upheld the trial court's findings, concluding there ...(Unlock)

Ratio:

  • The Supreme Court found no merit in the petition, noting that the burden of proof shifted to Del Rosario after he admitted to killing Sinco.
  • Del Rosario needed to establish self-defense elements: unlawful aggression, reasonable necessity of means, and lack of sufficient provocation.
  • The Court deemed Del Rosario's account implausible, especially given the history of animosity with the victim.
  • Lack of corroborating evidence for his claim of being shot first weakened his defense.
  • The nature and number of gunshot wounds (eight total) indicated inten...continue reading

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