G.R. No. 220486 - People vs. Corpuz y Daguio

Appellant Elinjer Daguio Corpuz was charged with the murder of Jerry Corpuz under allegations that, on September 2, 2011, at about 4:00 in the afternoon, he, armed with a gun, shot the victim with treachery and evident premeditation.
The killing allegedly occurred at Brgy. Padapada, Sta. Ignacia, Tarlac, Philippines, within the jurisdiction of the court.

The case was raffled to Regional Trial Court, Branch 68, Camiling, Tarlac.
Upon arraignment, appellant pleaded “not guilty.”
Trial proceeded with the presentation of evidence by both the prosecution and the defense.

Narrated that on the day of the incident, her husband, Jerry Corpuz, left the house, rode his motorcycle to buy feeds, and was flagged down by Porfirio Corpuz, Jr.
Described witnessing a heated altercation between Jerry and Porfirio, with the situation escalating as they pushed each other.
Noted that while her husband was pinned to the ground by Porfirio, appellant appeared wielding a gun and shot Jerry twice.
Observed that after the shooting, appellant fled into the fields.

Corroborated his mother's account by confirming the sequence of events, including hearing two gunshots and identifying appellant as the shooter.
Reported the positions of the parties at the scene: the victim lying bloodied on the ground, appellant moving away holding the gun, and Porfirio standing nearby.

Appellant claimed that on the incident day he was cooking inside his house and later went out to gather malunggay leaves.
He testified that he saw his brother Porfirio with a “pamalo and pamingwit ng palaka” and noticed Jerry’s motorcycle parked by the roadside.
According to his version, an altercation ensued when Jerry blocked his path and provoked him verbally.
Appellant asserted that in the ensuing struggle—during which both he and the victim wrestled for a .38 caliber gun—an accidental discharge occurred when he attempted to grab the firearm, and another shot was fired as the fight continued.

The trial court gave full credence to the testimonies of the prosecution witnesses, finding their accounts spontaneous, categorical, and credible.
It ruled that treachery attended the killing since appellant approached the victim, who was pinned down by his own brother, and shot him suddenly, thus depriving him of any chance to defend himself.
Appellant was convicted of murder under Article 248 of the Revised Penal Code and sentenced to reclusion perpetua.
The decision also awarded monetary sums: Php75,000.00 as civil indemnity, Php50,000.00 as moral damages, Php30,000.00 as exemplary damages, and Php100,000.00 as actual damages.

Appellant appealed the trial court’s decision, contesting the sufficiency and consistency of the prosecution evidence as well as asserting that the fatal shooting was accidental.
The Office of the Solicitor General (OSG) defended the trial court’s findings, emphasizing the unambiguous and straightforward testimonies of Ofelia and Jerick.
The Court of Appeals, in its decision dated February 18, 2015, affirmed the conviction with modifications regarding the award of damages (deleting actual damages and substituting with temperate damages).

Appellant seeks affirmative relief for his acquittal by reiterating his defense that the shooting was accidental.
Both parties adopted their respective briefs in compliance with a resolution, leading to the present appeal before the Supreme Court.

Whether the Court of Appeals erred in affirming appellant’s conviction for murder.

The core issue involves the assessment of whether the factual findings of the trial court—particularly the identification of appellant as the shooter and the demonstration of treachery—were properly sustained.
The question also encompasses the adequacy of evidence refuting appellant’s assertion that the killing was accidental.

Whether there was sufficient evidence to establish that the killing was committed with treachery and not merely an accidental discharge during a struggle.

Analysis on whether appellant’s actions—sudden, swift, and unexpected in the midst of an altercation—amounted to a deliberate and cold-blooded killing.
Consideration of the requirement of evident premeditation and if its absence affects the qualification of the murder charge.