Facts:

• Regie Labiaga alias "Banok" was charged with murder and frustrated murder.
• The incidents occurred on December 23, 2000, in Barangay Malayu-an, Ajuy, Iloilo.
• Labiaga, along with Alias Balatong Barcenas and Cristy Demapanag, allegedly conspired to shoot and kill Judy Conde and injure Gregorio Conde using an unlicensed firearm.
• Judy Conde died from gunshot wounds to her breast.
• Gregorio Conde sustained a gunshot wound to his right forearm but survived due to timely medical intervention.
• The Regional Trial Court (RTC) of Barotac Viejo, Iloilo, Branch 66, convicted Labiaga of murder and frustrated murder.
• Labiaga was sentenced to reclusion perpetua for the murder charge and a prison term ranging from six years and one day to ten years and one day for the frustrated murder charge.
• Demapanag was acquitted due to insufficient evidence.
• The Court of Appeals-Cebu (CA-Cebu) affirmed the RTC's decision with modifications, including the imposition of moral and exemplary damages.
• Labiaga appealed the decision, leading to the present case before the Supreme Court.

Issue:

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Ruling:

• The Supreme Court upheld the conviction of Regie Labiaga for murder.
• The Supreme Court modified the convictio...(Unlock)

Ratio:

• The Supreme Court rejected Labiaga's claim of self-defense, noting that he failed to provide clear and convincing evidence to support his assertion.
• His version of the incident was uncorroborated and contradicted by the positive identification of the prosecution's witnesses.
• The Court emphasized that the burden of proof shifts to the accused when claiming self-defense, and Labiaga's failure to present any other eyewitness or report the incident to the police further weakened his defense.
• The Court found the testimonies of the Condes credible and consistent, highlighting the trial court's unique position to assess witness credibility.
• Regarding the conviction for frustrated murder, the Supreme Court determined that the wound sustained by Gregorio Conde was not mortal, as confirmed by Dr. Edwin Figura's testimony.
• Since the wound was not life-threatening, the Court concluded that the appropriate conviction should be for attempted murder, not frustrated murder.
• The Court applied Article 6 of the Revised Penal Code, which defines the s...continue reading