Case Digest (G.R. No. L-25951)
Facts:
The case in question involves an appeal by Regie Labiaga (appellant) against the Decision dated October 18, 2011, rendered by the Court of Appeals-Cebu (CA-Cebu). The CA-Cebu upheld, with modifications, the Joint Decision dated March 10, 2008, of the Regional Trial Court (RTC) of Barotac Viejo, Iloilo, Branch 66, which had convicted Regie Labiaga of murder in Criminal Case No. 2001-1555 and of frustrated murder in Criminal Case No. 2002-1777. On December 23, 2000, Labiaga, along with alias Balatong Barcenas and Cristy Demapanag, was charged with murder and frustrated murder following a shooting incident in Barangay Malayu-an, Ajuy, Iloilo. According to the information, they conspired to kill Judy Conde (alias Jojo) using an unlicensed firearm, resulting in her death, while also attempting to kill Gregorio Conde, who suffered a non-fatal gunshot wound.
During the trial, the prosecution presented four witnesses, including the victims' family members, who testified about the e
Case Digest (G.R. No. L-25951)
Facts:
- Background of the Case
- The appellant, Regie Labiaga (alias aBanoka), was charged in two separate criminal cases:
- Criminal Case No. 2001-1555 for Murder with the Use of Unlicensed Firearm
- Criminal Case No. 2002-1777 for Frustrated Murder with the Use of Unlicensed Firearm
- Co-accused include a certain Alias Balatong Barcenas and Cristy Demapanag, with the latter later being acquitted due to insufficiency of evidence.
- Summary of the Charges and Alleged Acts
- In Criminal Case No. 2001-1555 (Murder Charge):
- The prosecution alleged that on or about December 23, 2000, within Barangay Malayu-an, Ajuy, Iloilo, the accused conspired and used an unlicensed firearm to shoot Judy Conde (alias aJojoa), targeting various parts of her body, causing fatal gunshot wounds.
- The act was characterized by treachery, evident premeditation, and deliberate intent to kill.
- In Criminal Case No. 2002-1777 (Frustrated Murder Charge):
- The prosecution charged that on the same day, the accused, with the same modus operandi, attacked Gregorio Conde by shooting him on the posterior aspect of his right forearm.
- It was contended that despite committing all acts of execution that would have produced murder, the crime was not consummated because timely and competent medical intervention saved the victim’s life.
- Prosecution’s Version of the Events
- Timeline of the Incident:
- At around 7:00 p.m. on December 23, 2000, the Conde family was at their residence in Barangay Malayu-an, Ajuy, Iloilo.
- Gregorio Conde left the house and was shot by the appellant from a distance of approximately five meters.
- Following the shooting of Gregorio, Judy Conde was also shot when she was summoned for help.
- Evidence Presented:
- Testimonies of two principal witnesses:
- Gregorio Conde (victim in Criminal Case No. 2002-1777)
- Medical evidence:
- Dr. Jeremiah ObaAana performed the autopsy on Judy Conde and confirmed death due to gunshot wounds leading to cardiopulmonary arrest.
- Defense’s Version of the Events
- The appellant admitted his presence at the scene but claimed that his actions were in self-defense.
- According to the defense:
- Gregorio Conde, allegedly armed with a shotgun, initiated aggression against the appellant.
- In a struggle where the shotgun jammed, the firearm discharged accidentally.
- The appellant contended that he was unaware if anyone was hit as a result.
- Corroborative Testimony:
- Demapanag and his brother, Frederick, supported an alibi and alternative account, particularly distancing Demapanag from the incident.
- Procedural History and Prior Rulings
- The Regional Trial Court (RTC) of Barotac Viejo, Iloilo (Branch 66) rendered a Joint Decision on March 10, 2008:
- Convicted the appellant for murder in Criminal Case No. 2001-1555 and frustrated murder in Criminal Case No. 2002-1777.
- Acquitted accused Cristy Demapanag due to insufficient evidence.
- The Court of Appeals-Cebu (CA-Cebu) affirmed the RTC’s decision with modifications, including the imposition of additional moral and exemplary damages, after distinguishing between civil indemnity (a fixed judicial award) and damages meant to compensate for mental anguish.
Issues:
- Sufficiency and Credibility of the Evidence
- Whether the evidence presented by the prosecution, including the testimonies of the Conde family members and the medical examinations, was credible enough to convict the appellant.
- Whether the defense’s version—asserting self-defense—and the uncorroborated nature of appellant’s assertions could create reasonable doubt.
- Characterization of the Crimes
- Whether the acts committed against Gregorio Conde should be deemed frustrated murder or attempted murder, given the nature of the injuries and the effect of timely medical intervention.
- Determining if all elements for consummated murder in Criminal Case No. 2001-1555 were adequately met, and if the requisite elements of treachery were present.
- Validity of the Self-Defense Claim
- Whether the appellant’s claim of having acted in self-defense holds, in view of his failure to present corroborative evidence or eyewitness testimony supporting a direct encounter or struggle.
- Whether the procedural lapses—such as failing to report alleged unlawful aggression—undermine his defense.
- Appropriateness of the Damages Awarded
- The correctness of awarding separate sums for civil indemnity, moral damages, and exemplary damages by both the RTC and the appellate court.
- Whether modifications imposed by the CA-Cebu and later by the Supreme Court appropriately adjusted these awards in view of recent jurisprudence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)