Facts:

The case involves Regie Labiaga, also known as "Banoka," who was charged with murder and frustrated murder in two separate criminal cases. The incidents occurred on December 23, 2000, in Ajuy, Iloilo, Philippines. In Criminal Case No. 2001-1555, Labiaga, along with co-accused Alias Balatong Barcenas and Cristy Demapanag, was accused of murdering Judy Conde, who was shot multiple times, resulting in her death. The information stated that the accused conspired and used an unlicensed firearm to carry out the attack with treachery and evident premeditation. In Criminal Case No. 2002-1777, the same individuals were charged with frustrated murder for shooting Gregorio Conde, Judy's father, who sustained a non-fatal gunshot wound due to timely medical intervention.

During the trial, both Labiaga and Demapanag pleaded not guilty. The prosecution presented four witnesses, including Gregorio Conde and his daughter Glenelyn, who testified about the events leading to the ...

Facts:

Incident Overview
On December 23, 2000, in Barangay Malayu-an, Ajuy, Iloilo, Regie Labiaga (appellant), along with Alias Balatong Barcenas and Cristy Demapanag, was charged with Murder and Frustrated Murder for shooting Judy Conde and Gregorio Conde, respectively. Judy died from her injuries, while Gregorio survived after medical treatment.

Prosecution’s Version

• At around 7:00 p.m., Gregorio Conde was outside his home when appellant shot him.
• Gregorio called for help, and his daughters, Judy and Glenelyn, rushed to his aid.
• Appellant shot Judy in the abdomen, causing her death.
• Appellant and his accomplices fled the scene after declaring, “She is already dead.”
• Judy was pronounced dead on arrival at the hospital, while Gregorio recovered from his injuries.

Defense’s Version

• Appellant claimed self-defense, alleging that Gregorio initiated the attack with a shotgun that jammed.
• During a struggle over the shotgun, it accidentally fired, and appellant claimed he did not know if anyone was hit.
• Demapanag asserted an alibi, stating he was 14 kilometers away at the time of the incident.

Medical Findings

• Dr. Jeremiah ObaAana conducted Judy’s autopsy, concluding her death was due to a gunshot wound causing cardiac tamponade.
• Dr. Edwin Figura examined Gregorio and found a non-serious gunshot wound on his right forearm and abrasions on his shoulder.

Issue:

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Ruling:

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Ratio:

1. Self-Defense

   • The burden of proof shifts to the accused when self-defense is invoked. Appellant’s uncorroborated and implausible claims failed to meet this burden.

2. Treachery

   • Treachery was present as the victims were unarmed and had no opportunity to defend themselves. The use of a shotgun against unarmed victims ensured their defenselessness.

3. Attempted vs. Frustrated Murder

   • For Frustrated Murder, the wound must be fatal without timely medical intervention. Since Gregorio’s wound was not life-threatening, the crime was only Attempted Murder.

4. Damages

   • Civil indemnity, moral damages, and exemplary damages were awarded to compensate the victims and their families for the harm suffered.