G.R. No. 241946 - People vs. Jaen y Morante

Elever Jaen y Morante (Jaen), accused-appellant, was charged with Murder under Article 248 of the Revised Penal Code (RPC).
The murder victim was Jacob Eduardo Miguel O. Manzo (Manzo).
SPO3 Freddie Cayot, Jr. (Cayot), a police officer and distant relative of Jaen, was a witness and involved party.

On July 13, 2013, Jaen, Cayot, and Manzo attended a ceremony at Camp Bagong Diwa in Bicutan.
After, Manzo solicited a ride home from Cayot, which was granted.

Upon arriving in San Juan City around 4:30 pm, Manzo invited Cayot and Jaen for drinks at his home.
Sgt. Rey Banzon and his nephew later joined their drinking session.
They proceeded to a resto-bar owned by Banzon in Mandaluyong City.
In the car, Cayot drove, Manzo was front passenger, and Jaen was seated at the back.
Cayot placed his 9mm Beretta service pistol inside his belt bag under the driver’s seat before driving.
At around 11:20 pm, after dinner and drinks, they prepared to leave.

While driving near Manzo’s home, Cayot heard a series of gunshots near his ear accompanied by smoke inside the car; he pulled over.
Blood was seen dripping from Manzo’s head.
Jaen said Manzo took the gun; Cayot panicked, initially believing Manzo committed suicide.
They took Manzo to his house, where Jaen acted fidgety and interrupted the family saying “Aaminin ko lahat. Sasabihin ko sa inyo!” (I will admit everything and tell you!).
Cayot stopped Jaen by slapping him.
Jaen excused himself several times to urinate, observed rubbing his hands on walls and grass, possibly trying to remove gunshot residue.
At the hospital, Jaen confessed to Cayot that he was the shooter, leading to his arrest.

Autopsy revealed six gunshot wounds on the posterior/occipital (back) region of Manzo’s head.
Wounds were distant gunshot wounds, indicating the shooter was about two feet away, likely seated in the back seat of the car.
Five cartridge cases and two deformed jackets matched the Beretta pistol’s ammunition, found at the back of the car.
Paraffin tests on Cayot, Jaen, and Manzo were negative for gunpowder residue.
Bullet trajectory examination indicated bullet marks on dashboard, glove compartment, front passenger door, and detachment of the windshield, suggesting likely shooter position at the rear passenger seat.

The Regional Trial Court (RTC) found Jaen guilty beyond reasonable doubt of Murder with the qualifying circumstance of treachery and sentenced him to reclusion perpetua.
The Court of Appeals (CA) affirmed the conviction with modifications increasing damages and adding interest.

Jaen appealed, challenging his conviction principally on inconsistencies and insufficiency of circumstantial evidence and credibility of the primary witness, Cayot.
The SC reviewed the facts, evidence, and arguments.

Whether Elever Jaen y Morante is guilty beyond reasonable doubt of Murder under Article 248 of the Revised Penal Code, considering the nature of the evidence (direct and circumstantial) and the presence of qualifying circumstance of treachery.