G.R. No. 229502 - People vs. Daroya

Rafael Daroya @ Raffy was charged in an Information dated February 18, 2003 for the killing of Rolando Songcuan.
The Information alleged that on or about October 19, 2002, in Dagupan City, Daroya, with treachery and intent to kill, attacked Rolando, causing injuries that led to his death from a head injury with massive hemorrhage.
The charge was filed under Article 248 of the Revised Penal Code (RPC), which concerns murder, while taking into consideration elements relating to Republic Act No. 7659.

Dr. Benjamin Marcial Bautista, whose post-mortem examination confirmed that the cause of death was “massive hemorrhage” due to head injuries.
Herminina Songcuan, the victim’s mother, who provided relevant background and context.
Arnel Ceralde, a pedicab driver, who witnessed the incident and identified Daroya as the assailant holding a piece of metal wrapped in a towel and repeatedly punching Rolando until he fell.

The evidence indicated that after Daroya’s attack, the victim was left unable to defend himself, and subsequent efforts by fellow drivers to seek medical assistance proved futile as Rolando later died in hospital.

Daroya admitted to having punched Rolando but contended that he acted in self-defense.
He claimed the confrontation arose from a dispute over queue positioning among pedicab drivers, where Rolando allegedly parked his pedicab in a manner that interfered with his turn.
Daroya asserted that Rolando was the aggressor by initiating the altercation.

On February 24, 2014, the RTC, Dagupan City, Branch 42, rendered a Decision finding Daroya guilty beyond reasonable doubt of murder under Article 248 RPC.
The RTC relied on ascertained facts including Daroya’s sudden attack, the use of a metal wrapped in a towel, and the victim’s inability to defend himself.
The RTC also determined that the qualifying circumstance of treachery was present, leading to the imposition of reclusion perpetua and ordered monetary awards (civil indemnity, moral damages, actual damages, temperate damages, and exemplary damages) to the victim’s heirs.

The sufficiency of evidence proving all elements of murder, particularly the rejection of his claim of self-defense.
The appreciation and finding of treachery as a qualifying circumstance.

On February 15, 2016, the Court of Appeals reaffirmed the conviction with modification:

The conviction was adjusted from murder to homicide, acknowledging that the required qualifying circumstance of treachery was not sufficiently established.
Monetary awards were modified; civil indemnity and moral damages were reduced, and exemplary damages were deleted.

Both Daroya and the Solicitor General consented to the briefs adopted in the appellate court proceedings.

Whether the Court of Appeals erred in affirming the RTC’s conviction of murder by finding all essential elements, especially the qualifying circumstance of treachery, present in the killing of Rolando Songcuan.

Whether Daroya’s claim of self-defense, asserting that Rolando initiated the altercation and that his response was necessary, met the legal requirements for a justifying circumstance.

Whether the evidentiary basis for establishing treachery – namely the suddenness and the method of attack – was adequate to support a murder conviction as opposed to a homicide conviction.