G.R. No. 139603 - Quinao vs. People

On 28 September 1996, at about 4:00 o’clock in the afternoon, a confrontation occurred in front of Vicente Madriaga’s residence at Pag-asa, Camarin, Caloocan City.
Vicente Madriaga and his friend Allan were playing chess, while several others—Noli Madriaga (Vicente’s son), Noel Madriaga (Vicente’s grandson), and neighbor Angel Soliva—were present.
Henry Almazan unexpectedly arrived at the scene accompanied by his friend Johnald Molina, driven by the suspicion that his fighting cocks had been stolen and that Angel Soliva was involved.
Almazan’s provocation was set in motion by the remark and threat (“manos-manos na lang tayo”) indicating an impending escalating violence.

Initially, Almazan attempted to shoot Angel Soliva with his .38 caliber revolver; however, the weapon misfired on two successive attempts.
Following the failed attempts, when Vicente Madriaga tried to pacify the situation, Angel fled and Almazan redirected his gun at Noli Madriaga, who pleaded for mercy for himself and his daughter.
Almazan fired at Noli, hitting him on the left side of his stomach and sending him crashing to the ground.
Subsequently, Almazan shot Noel Madriaga on the left thigh; though the injury was serious enough to cause him to limp and eventually fall, Noel survived.
Neighbors assisted in transporting the injured victims to the hospital. Noli, however, succumbed to his injuries before hospital admission, while Noel was discharged the same day due to his wound being classified as minor.

Dr. Ma. Cristina Freyra’s autopsy confirmed that Noli’s cause of death was attributable to a gunshot wound to the trunk from a .38 caliber revolver.
Dr. Misael Jonathan Ticman asserted that although Noel sustained a gunshot wound to the left thigh, it was minor and expected to heal within a week; he noted, however, that the injury could have resulted in infection or death if not treated timely.
Prosecution witnesses, including Vicente and Noel Madriaga, consistently identified Almazan as the aggressor, detailing his unprovoked and sudden use of lethal force.
The defense produced conflicting testimony, with some witnesses (notably Johnald Molina) attempting to shift blame to Angel Soliva. Almazan’s own account claimed that during an altercation with Angel—who allegedly fired his weapon—he was forced into using deadly force only in self-defense.

The prosecution version maintained that Almazan acted out of vengeance over the theft of his fighting cocks and deliberately attacked the defenseless victims without prior provocation.
The defense contended that Almazan’s actions were precipitated by self-defense following an unexpected armed confrontation initiated by Angel Soliva, and that the bloodshed was accidental rather than deliberate.
Evidence of a struggle involving Angel Soliva, corroborated by Johnald Molina, was presented in defense, though the credibility of this testimony was later questioned due to bias arising from friendship.
After the incident, Almazan went into hiding, only being apprehended eight months later by police agents from the Western Police District.

Two separate Informations were filed against Almazan: one charging him with murder (Crim. Case No. C-51276) for the death of Noli Madriaga and another charging him with frustrated murder (Crim. Case No. C-51277) for shooting Noel Madriaga, whose wound was non-fatal due to prompt medical attention.
The trial court found sufficient motive, given the theft of fighting cocks, and positively identified Almazan as the assailant.
In Crim. Case No. C-51276, Almazan was convicted of murder with treachery as a qualifying circumstance, resulting in a sentence of reclusion perpetua (later reduced from the death penalty) along with accessory penalties and indemnity payments.
In Crim. Case No. C-51277, he was initially convicted of frustrated murder; however, upon review, the conviction was modified to attempted murder due to the minor character of Noel’s injury.
The trial court also considered the mitigating circumstance of passion and obfuscation but ultimately upheld the enhanced penalty for the qualifying circumstance of treachery.

Whether the evidence presented by the prosecution was sufficient to prove beyond reasonable doubt that Henry Almazan committed the acts of murder and frustrated (later reclassified as attempted) murder.

The role and sufficiency of the identification and testimony of prosecution witnesses.
The effect of potentially discreditable or hearsay elements in the testimony, such as that of Shirley Abordo.

Whether the defense’s conflicting narrative—including the claim that Angel Soliva was the actual shooter and that Almazan acted in self-defense—could create reasonable doubt.

The reliability and corroboration of defense testimony given by Johnald Molina.
Whether the alleged inconsistencies in the defense accounts warranted reversal or modification of the conviction.

Whether the presence or absence of aggravating circumstances like treachery and evident premeditation were correctly determined by the trial court.

The significance of the victims being unarmed and unprovoked in establishing treachery.
The evidentiary threshold required to ascertain premeditation.

Whether the nature of Noel Madriaga’s injury justified a conviction for frustrated murder or whether it should be reduced to attempted murder.

The role of medical testimony in assessing the fatality of the injury.
The legal standard for distinguishing between a fatal and a non-fatal wound in homicide cases.

Whether the trial court properly evaluated the credibility of the witness testimonies, taking into account its unique position to observe witness demeanor.