Facts:

The case involves the accused-appellant Alberto D. Carpio and the deceased Federico A. Cunanan. The incident occurred on September 24, 1989, in Barangay De la Paz, Lubao, Pampanga, Philippines. The Regional Trial Court of Pampanga, Branch 52, found Carpio guilty of murder, qualified by treachery, and sentenced him to reclusion perpetua. Additionally, Carpio was ordered to pay the heirs of Cunanan various damages totaling P185,000.

The prosecution's evidence revealed that on the day of the incident, Cunanan was conversing with several individuals near a basketball court when Carpio, who was nearby, followed Cunanan's group after they dispersed. Carpio returned to his house, retrieved a homemade .22 caliber pistol, and shot Cunanan three times from behind as he walked away. Cunanan fell to the ground and was later taken to a hospital, where he identified Carpio as his assailant before succumbing to his injuries. Carpio fled but was apprehended later, where he admitte...

Facts:

Incident Details

• On September 24, 1989, between 11:00 and 11:30 AM, Federico A. Cunanan and his group were talking in front of a basketball court in Barangay De la Paz, Lubao, Pampanga. Accused-appellant Alberto Carpio was nearby, also conversing with others.
• After the group dispersed, Federico Cunanan left with Eduardo Cunanan and Carlito Mangalindan. Carpio, accompanied by Rodrigo Mangalindan and another person, followed them.
• Upon reaching his house, Carpio went inside, retrieved a homemade .22 caliber pistol, and overtook Cunanan’s group. He then shot Cunanan three times from behind, causing him to fall to the ground. Cunanan was later taken to the hospital but died from his injuries.

Arrest and Investigation

• Carpio fled the scene but was later apprehended in Floridablanca, Pampanga. He admitted to shooting Cunanan and led the police to the location of the gun used in the crime.
• During the investigation, Carpio admitted to the shooting but refused to provide a formal statement. Witnesses, including Eduardo Cunanan and Carlito Mangalindan, corroborated the prosecution’s version of events.

Defense’s Claim

• Carpio admitted to killing Cunanan but claimed self-defense. He alleged that Cunanan had threatened him with a gun over a dispute involving lost ducks. Carpio claimed he wrestled the gun from Cunanan, and it accidentally discharged, killing Cunanan.

Trial Court’s Findings

• The trial court found Carpio’s self-defense claim unconvincing. It noted inconsistencies in his testimony and the lack of corroborating witnesses. The court also found that the killing was attended by treachery, as Cunanan was shot from behind without warning.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Self-Defense Claim Unsubstantiated

   • Carpio failed to prove the essential elements of self-defense by clear and convincing evidence. His testimony was self-serving and contradicted by the physical evidence, particularly the post-mortem findings that the victim was shot from behind.
   • The burden of proof lies on the accused to establish self-defense, and Carpio’s evidence was insufficient to meet this burden.

2. Treachery as a Qualifying Circumstance

   • The Court agreed with the trial court’s finding that the killing was attended by treachery. Carpio’s attack was sudden, deliberate, and executed from behind, ensuring that the victim had no opportunity to defend himself.
   • The requisites for treachery—(1) the use of means to ensure the offender’s safety and (2) the deliberate choice of such means—were both present in this case.

3. Credibility of Witnesses

   • The Court upheld the trial court’s assessment of the credibility of the prosecution witnesses. Their testimonies were consistent and corroborated by physical evidence, while Carpio’s defense lacked corroboration and was inherently weak.

4. Finality of Trial Court Findings

   • The Supreme Court reiterated its policy of not disturbing the factual findings of trial courts, especially on matters of witness credibility, unless there is a clear showing of oversight or misinterpretation. No such errors were found in this case.

Conclusion:

The Supreme Court affirmed Carpio’s conviction for murder, emphasizing that his self-defense claim was unsupported by evidence and that the killing was qualified by treachery. The decision underscores the importance of credible evidence in justifying self-defense and the necessity of proving treachery beyond reasonable doubt.