Facts:

In the case of People of the Philippines vs. Ernesto G. De Leon @Erning Demoniyo, decided by the Third Division of the Supreme Court on September 26, 1996, the accused-appellant Ernesto G. De Leon was charged with the murder of Albert Capistrano y Araullo. Following a trial in the Regional Trial Court of the National Capital Judicial Region (Branch 72, Caloocan City), the court found the accused-appellant guilty beyond a reasonable doubt of the offense of murder. The trial led to a sentence of reclusion perpetua for De Leon, along with an order to indemnify the victim's heirs ₱50,000.00 for loss of life and ₱75,000.00 for related expenses.

The incident occurred on March 1, 1992, around 1:00 PM, at the residence of the Capistrano family on Jeffrey Street, Gabriel Subdivision, Hulong Duhat, Malabon, Metro Manila. During this time, Alvin Capistrano, a fourteen-year-old boy, was at home with his mother, Violeta, and sister, Agnes, when De Leon burst in, armed with a gun and dema

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Facts:

Background and Context

• On March 1, 1992, at around one o’clock in the afternoon, the events unfolded at the residence located at No. 2 Jeffrey Street, Gabriel Subdivision, Hulong Duhat, Malabon, Metro Manila.
• At the time, Alvin Capistrano—a 14-year-old boy—was inside the house accompanied by his mother, Violeta, and his sister, Agnes.

Entry and Disruptions by the Accused

• Accused-appellant Ernesto G. de Leon (also known as Erning Demonyo) suddenly arrived on the scene holding a gun and shouting “Nasaan ang asawa ko?” ("Where is my wife?").
• He proceeded to create a disturbance by throwing items around the house, thereby exacerbating the tension within the victim’s family environment.

Escalation of the Incident

• In an attempt to pacify the accused-appellant, Alvin fetched his father who was attending a nearby baptismal party and had been serving as one of the sponsors.
• As Alvin and his father were returning home, they encountered the accused again.
• During this encounter, the accused-appellant suddenly directed his attention to Alvin by poking a gun at his forehead, and immediately after, he turned towards Alvin’s father and shot him twice.

Aftermath and Witness Evidence

• Alvin witnessed his father being shot and falling to the ground, and he later ran to seek help from nearby neighbors.
• Alvin recounted hearing a total of six shots emanating from the place where his father was attacked.
• It was noted that the incident was not isolated in nature; the accused had previously caused disturbances by uttering invectives and pointing his gun at members of the Capistrano family on several occasions.
• The medico-legal officer, Dr. Valentin Bernales of the National Bureau of Investigation (NBI), conducted an autopsy on the victim, Alberto Capistrano, confirming death by gunshot wounds as documented in exhibits H, H-1, and H-2.

Contentions Raised by the Accused-Appellant

• The accused-appellant contested the trial court’s reliance on the sole testimony of Alvin Capistrano as sufficient evidence for a conviction beyond reasonable doubt.
• He argued that Alvin’s account was improbable and inconsistent with typical human behavior under duress, suggesting that a 14-year-old child might not naturally act by calling for help in such circumstances.
• The accused-appellant further argued that the absence of physical injury on Alvin’s head did not corroborate the claim that a gun was poked at his forehead, thereby attempting to cast doubt on this element of the testimony.
• Despite these defenses, the natural reaction of a child, as well as the consistency of Alvin’s account with the established facts and previous conduct of the accused, formed a pivotal part of the evidence.

Issue:

Credibility and Sufficiency of Witness Testimony

• Whether the trial court erred in relying solely on the testimony of a 14-year-old witness, Alvin Capistrano, to establish the guilt of the accused beyond reasonable doubt.
• Whether Alvin’s natural and instinctive reaction during a traumatic incident should undermine the weight of his testimony.

Establishment of Qualifying Circumstances

• Whether the trial court properly determined that treachery, as a qualifying circumstance for murder, was present during the commission of the crime.
• Whether there was clear and convincing evidence to prove that the accused-appellant employed treacherous means in executing the crime.

Appropriate Classification of the Crime

• Whether the crime committed by the accused-appellant should be classified as murder or, in view of the evidence and absence of premeditation, as homicide.
• Whether the imposition of a reclusion perpetua sentence in the original trial was justified in light of the revised circumstances supporting homicide only.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)