Title
People vs. Dagani y Reyes
Case
G.R. No. 153875
Decision Date
Aug 16, 2006
Two PNR security officers shot a man during a canteen altercation; claims of self-defense and duty rejected. Crime downgraded to Homicide; one acquitted, one convicted.

Case Digest (G.R. No. L-47851)
Expanded Legal Reasoning Model

Facts:

Incident Overview:

  • On September 11, 1989, in Manila, Philippines, accused-appellants Rolando Dagani y Reyes (Dagani) and Otello Santiano y Leonida (Santiano), both security officers of the Philippine National Railways (PNR), were involved in the shooting death of Ernesto Javier y Felix (Javier).
  • The prosecution alleged that the appellants conspired to kill Javier with evident premeditation and treachery.

Prosecution's Version:

  • At around 4:45 PM, Javier and his companions were drinking at a canteen inside the PNR compound.
  • Appellants entered the canteen, and Dagani shoved one of Javier's companions, causing him to fall. Dagani then held Javier while Santiano shot him twice, resulting in fatal wounds.

Defense's Version:

  • Appellants claimed they were investigating a commotion at the canteen as part of their official duty.
  • Dagani approached Javier, who allegedly pulled out a .22 caliber revolver and attempted to fire at Dagani, but the gun failed to discharge.
  • Santiano, hearing gunfire, saw Javier and Dagani grappling for the gun. Santiano fired a warning shot and then shot Javier twice, claiming self-defense and lawful performance of duty.

Trial Court Findings:

  • The Regional Trial Court (RTC) found appellants guilty of Murder, citing treachery and conspiracy. The court rejected their claims of self-defense and lawful performance of duty.
  • The RTC sentenced them to an indeterminate prison term and ordered them to pay damages to Javier's heirs.

Court of Appeals (CA) Decision:

  • The CA affirmed the RTC's findings but modified the penalty to reclusion perpetua, deleting the award of attorney's fees and appearance fees.

Issues:

  • Whether the appellants acted in self-defense.
  • Whether the appellants were in the lawful performance of their official duties.
  • Whether there was conspiracy between the appellants.
  • Whether the prosecution proved beyond reasonable doubt that the appellants are guilty of Murder.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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