Facts:

The case involves Florencio Del Rosario as the petitioner and the People of the Philippines as the respondent. The events transpired on August 7, 1993, in Cabugao, Ilocos Sur, where Del Rosario, along with several co-accused, was charged with murder for the killing of Remy Sinco. The information was filed by the provincial prosecutor on November 8, 1993, alleging that the accused conspired to kill Sinco with treachery and evident premeditation. During the trial, the prosecution presented witnesses including Lorna Sinco, the victim's spouse, and police investigators, who testified that Sinco was attacked and shot at point-blank range by the accused while he was held by others. The defense, led by Del Rosario, claimed self-defense, asserting that Sinco had shot him first. The trial court found Del Rosario guilty of homicide, not murder, and acquitted the co-accused due to lack of evidence of conspiracy. The Regional Trial Court sentenced Del Rosario to an indeterminate pena...

Facts:

Incident Overview

• On August 7, 1993, in Cabugao, Ilocos Sur, Florencio Del Rosario, along with Edilberto, Alejandro, Emilio, Antonio (all surnamed Del Rosario), and Tomas Abolero, were charged with murder for the killing of Remy Sinco. The prosecution alleged that the accused conspired and shot Remy Sinco with illegally possessed firearms, resulting in his death.

Prosecution’s Version

• The prosecution presented witnesses, including Lorna Sinco (the victim’s spouse), Oliver Sinco (the victim’s son), Edgar Sinco (the victim’s nephew), Dr. Rudy Singson (Rural Health Physician), and Rodolfo Somera (Chief Investigator of the Cabugao Police Station).
• According to the prosecution, on the night of the incident, Remy Sinco and his family passed by the house of Emilio Del Rosario, where the accused were drinking. After buying fish, they returned the same way. Suddenly, Emilio, Alejandro, Antonio, and Tomas held Remy’s arms, while Florencio and Edilberto shot him at point-blank range. Remy died from multiple gunshot wounds.

Defense’s Version

• Florencio Del Rosario admitted to killing Remy Sinco but claimed self-defense. He testified that Remy had shot him first, hitting his right leg, and he retaliated in self-defense. The other accused denied involvement in the killing.

Trial Court’s Findings

• The trial court convicted Florencio Del Rosario of homicide, not murder, and acquitted the other accused due to lack of evidence of conspiracy. The court rejected Florencio’s self-defense claim, finding no proof of unlawful aggression by the victim or reasonable necessity of the means used.

Court of Appeals’ Decision

• The Court of Appeals affirmed the trial court’s decision, ruling that Florencio failed to prove self-defense. The appellate court noted that Florencio’s testimony was uncorroborated and inconsistent with human behavior, and no gun was recovered from the victim.

Issue:

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Ruling:

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Ratio:

1. Burden of Proof in Self-Defense: When an accused invokes self-defense, the burden of proof shifts to them to establish the elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. Florencio failed to meet this burden.
2. Uncorroborated Testimony: Florencio’s claim that the victim shot him first was uncorroborated and inconsistent with the evidence, as no gun was recovered from the victim, and the shells found at the scene matched Florencio’s firearm.
3. Nature of Wounds: The victim sustained eight gunshot wounds, including fatal wounds to the head, chest, and stomach, which contradicted Florencio’s claim of self-defense and indicated a deliberate intent to kill.
4. Absence of Qualifying Circumstances: The crime was properly classified as homicide, not murder, as the prosecution failed to prove treachery or evident premeditation.
5. Penalty and Indemnity: The penalty imposed was within the range prescribed by law, and the death indemnity of P50,000.00 was consistent with prevailing jurisprudence.