Case Digest (G.R. No. L-30489)
Facts:
The People of the Philippines, Plaintiff and Appellee, vs. Alberto Macaso, Defendant and Appellant, G.R. No. L-30489, June 30, 1975, the Supreme Court En Banc, Martin, J., writing for the Court. The case comes to the Court for mandatory review of a condemnatory judgment of the Court of First Instance of Basilan in Criminal Case No. 1529.The accused, Alberto Macaso, was a patrolman of the Basilan City Police Department. The victim, Nicolas B. Suaso, a former detective corporal who had resigned and thereafter drove an auto jeep owned by his mother, and Macaso had several prior confrontations over traffic and parking enforcement in September and October 1964. On October 19, 1964, after a morning altercation at the wharf and further confrontations later that day, Inspector Fortuno Ramos intervened and ordered Suaso to move his jeep. A subsequent encounter in front of the City Bakery escalated: Suaso refused to surrender his license, exchanged insults with Macaso, then alighted from his jeep and rushed toward Macaso. Macaso fired several shots, and Suaso died of internal hemorrhage caused by multiple gunshot wounds; the medical testimony identified four distinct wounds (three with identified entry/exit trajectories and one tangent wound).
At trial before the Court of First Instance of Basilan, the prosecution charged Macaso with murder under Article 248 in relation to paragraphs 13 and 16 of Article 14 (aggravating circumstances). The trial court found treachery and evident premeditation and convicted Macaso of murder, sentencing him to death, ordering indemnity of P12,000 to the heirs, and imposing costs. Macaso appealed, arguing (among others) legitimate self-defense, absence of treachery and premeditation, and that, at most, he should be convicted of a lesser offense.
On mandatory review, the Supreme Court examined the record, including eyewitness testimony and the medical report, and considered the parties’ contentions and applicable doctrine, notably the three-element test for self-defense and...(Subscriber-Only)
Issues:
- Did the accused establish legitimate self-defense?
- Were the aggravating circumstances of treachery and evident premeditation proven?
- If treachery and evident premeditation are not proven but mitigating circumstances exist, what is the proper classification of the crime and th...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)