Title
Ilisan y Piabol vs. People
Case
G.R. No. 179487
Decision Date
Nov 15, 2010
Ilisan convicted of homicide for shooting Gaton during a baptismal altercation; witness credibility upheld, paraffin test deemed inconclusive, damages adjusted.

Case Digest (G.R. No. 262938)
Expanded Legal Reasoning Model

Facts:

  • Background and Incident Setting
    • On February 3, 2002, during a baptismal celebration held at the residence of Ricky Silva in Barangay Nagkaisang Nayon, Novaliches, Quezon City, attendees were divided into different groups.
    • Among the guests were petitioner Romeo Ilisan y Piabol and Joey Gaton, who belonged to separate groups.
  • Triggering of the Altercation
    • While both groups engaged in a drinking spree, a confrontation arose when one of petitioner’s companions was reportedly irked by the way Joey Gaton looked at him.
    • The provoked companion’s reaction led to a melee involving members of the conflicting groups.
  • The Fatal Incident
    • Amid the ensuing melee, petitioner actively participated and eventually shot Joey Gaton in the abdomen.
    • The shooting, executed with a .45 caliber pistol, resulted in Joey Gaton’s instantaneous death.
  • Initiation of Criminal Proceedings
    • On February 7, 2002, an Information for murder was filed against petitioner before the RTC of Quezon City, Branch 81.
    • Petitioner pleaded not guilty when arraigned on March 18, 2002, insisting on his non-involvement.
  • Presentation of Evidence at Trial
    • Prosecution Evidence
      • The primary evidence was based on the testimonies of three key eyewitnesses:
        • Gabriel Gaton, the victim’s brother, who was summoned to the scene while the victim was being mauled.
ii. Marlon Dellamas, a neighbor who went to the scene to locate his brother during the altercation. iii. Edgardo Dag-um, another neighbor who witnessed the events near the location of the shooting.
  • These witnesses clearly identified petitioner as the gunman and described his actions in detail.
  • Defense Evidence
    • Petitioner and his witnesses (Jomarie Ilisan and Jaime Escasinas, his brother and cousin, respectively) contended that another guest, Chito Partisala, was the actual assailant.
    • The defense also presented Engineer Leonard Jabonillo, a forensic chemist, who testified that petitioner tested negative for gunpowder residue in paraffin tests conducted a day after the incident.
  • Findings of the Lower Courts
    • The Regional Trial Court (RTC) on June 14, 2005, after weighing the evidence, gave more credence to the positive identification and testimonies of the prosecution witnesses over the defense’s claims.
    • Concluding that there was insufficient evidence to sustain an allegation of treachery and premeditation, the RTC convicted petitioner of homicide under Article 249 of the Revised Penal Code.
    • The RTC imposed an indeterminate sentence ranging from eight years and one day of prision mayor (minimum) to fourteen years and eight months of reclusion temporal (maximum) and mandated the payment of damages to the victim’s heirs (P75,000.00 actual damages, P50,000.00 for death, and P50,000.00 as moral damages).
    • On appeal, the Court of Appeals (CA) in its August 23, 2007 decision affirmed the RTC’s conviction, modifying only the maximum period of the sentence and reducing the award for actual damages (later modified on review).
  • Detailed Testimonies
    • Gabriel Gaton
      • Testified that upon being informed of the melee, he and others went to the scene where he saw a man pointing a gun at his brother and subsequently heard the gunshot.
      • Provided specific details regarding distances and positions during the incident.
    • Marlon Dellamas
      • Stated that he was nearby when the incident occurred and observed the armed confrontation.
      • Described clearly his proximity to the shooter and confirmed that Joey Gaton fell after being shot.
    • Edgardo Dag-um
      • Recalled hearing shouts and went outside, where he witnessed the melee and observed that petitioner fired the gun.
      • Identified petitioner as the shooter from a close distance, corroborating the testimonies of the other witnesses.
  • Forensic and Documentary Evidence
    • The paraffin test conducted on petitioner a day after the incident yielded negative results for gunpowder residue.
    • Despite this result, the Court noted that such tests are generally unreliable in conclusively determining whether a person discharged a firearm.
    • Receipts and documentary evidence were later used to substantiate the actual expenses incurred for the victim’s burial and other related expenses.
  • Conclusive Findings
    • Both the RTC and the CA uniformly sided with the prosecution’s version of the events based on the eyewitness testimonies.
    • The courts found no substantial evidence to support the defense’s claim that another person, Chito Partisala, was the true perpetrator.
    • The negative paraffin test was not given sufficient weight to overturn the clear and consistent eyewitness accounts.

Issues:

  • Whether the trial and appellate courts erred in giving more weight to the eyewitness testimonies over the defense’s presentation of the negative paraffin test results.
  • Whether the credibility of the prosecution witnesses was unduly questioned by the petitioner due to alleged biases arising from their relationships with the victim and other participants.
  • Whether the evidence presented was sufficient to establish petitioner’s guilt beyond reasonable doubt, particularly in light of the conflicting testimony by the defense.
  • Whether the imposition of the indeterminate sentence, including the specific ranges for prision mayor and reclusion temporal, and the awards for civil indemnity and moral damages, were in conformity with the applicable laws and jurisprudence.
  • Whether the adjustment of the actual damages award—from the CA’s original figure to the increased amount based on documentary evidence—was correct and justified.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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