G.R. No. 128126 - People vs. Catapang

Accused Rafael M. Catapang was charged with the murder of Rictorino Aventurado.
The Regional Trial Court, Lucena City, Branch 54, convicted Catapang of murder, imposing reclusion perpetua and ordering payment of various damages to the victim’s heirs.
The charges included not only the killing but also additional financial penalties for unrealized income, death indemnity, actual burial expenses, and moral damages.

Rictorino Aventurado boarded a tricycle in Candelaria, Quezon, around 9:30 p.m.
Tricycle driver Jonathan Garcia observed a person armed with a .45 caliber handgun pointing at Aventurado.

Garcia noted that the accused fired at least seven successive shots at the victim.
The scene was well illuminated by a nearby Meralco post, allowing Garcia to clearly see the assailant.

After the shooting, the assailant fled while still holding his firearm.
Garcia assisted the wounded victim by transporting him to Bolanos Hospital, where Aventurado was pronounced dead.

Security guards Joselito Conyado and Pedrito Mandigma, while on duty nearby, witnessed a person holding a handgun running past under a fluorescent light source.
Later, under police investigation, both guards identified Rafael Catapang in a lineup as the man initially seen with a gun.
Medical examination revealed 11 entry and 9 exit wounds on the victim, with the positioning of the wounds indicating that the gunman was positioned higher or to the right of Aventurado.
A paraffin test conducted by the PNP Crime Laboratory showed that accused Catapang tested positive for gunpowder residue.

Accused Catapang claimed that he was asleep at his residence at the time of the incident.
He explained his positive paraffin test by alleging that he had fired a .38 caliber firearm earlier during a baptismal party on the same day.
Although he admitted that his house was only about 150 meters from the scene of the crime, his wife’s testimony was inconclusive regarding his whereabouts during the shooting.

The trial court found the eyewitness testimonies, particularly that of Jonathan Garcia, to be credible given the adequate lighting and absence of improper motives.
The court interpreted the rapid, unexpected, and unopposed nature of the shooting as constituting treachery, a qualifying circumstance for murder.
In addition to convicting Catapang of murder under Article 248 of the Revised Penal Code, the trial court ordered damages:

The lack of substantial evidence to support the claimed amount for actual expenses led to adjustments in the awards.

Accused-appellant contended that the eyewitness, Garcia, could not have properly identified a fleeing person under the described conditions.
Catapang argued that the supposed rapid sequence of events made accurate identification impossible.
The defense maintained that his alibi—being asleep at his residence—was not disproved beyond doubt, despite his proximity to the crime scene.
The appeal also focused on the proper computation and justification of the financial awards granted to the victim’s heirs.

Whether the illumination provided by the electric post was sufficient for an accurate identification of the assailant by Jonathan Garcia.
Whether any improper motive existed on the part of Garcia that could have tainted his testimony.

Whether Catapang’s claim that he was asleep at home, merely 150 meters from the scene, can be corroborated effectively.
Whether the evidence conclusively negates his alibi considering the circumstantial proximity to the crime scene.

The Establishment of Treachery and Its Impact on Qualifying the Crime as Murder

Whether the manner of the shooting, including the rapid and unexpected attack, qualifies as treachery under the Revised Penal Code.

Whether the trial court was justified in awarding the specific amounts for death indemnity, actual expenses, and moral damages.
Whether the alleged unrealized income due to the victim’s death was properly supported by evidence.