Title
Supreme Court
People vs. Pansensoy
Case
G.R. No. 140634
Decision Date
Sep 12, 2002
Roberto Pansensoy, convicted of murder for shooting Hilario Reyes, claimed self-defense. The Supreme Court reduced the charge to homicide, citing passion and obfuscation, and modified penalties and damages.

Case Digest (G.R. No. 140634)
Expanded Legal Reasoning Model

Facts:

  • Background and Charge
    • On May 8, 1994, in Antipolo City, Roberto Pansensoy (appellant) allegedly shot Hilario Reyes with a .38 caliber handgun, inflicting a fatal gunshot wound to the forehead.
    • An Information for murder, citing treachery and evident premeditation, was filed; appellant pleaded not guilty and trial ensued before RTC Branch 73, Antipolo City.
  • Prosecution Evidence
    • Analie Pansensoy (appellant’s wife): Eyewitness testimony that appellant arrived holding a gun, embraced by her attempt to disarm him, then approached Reyes, counted “one…two…three,” and shot him.
    • Dr. Emmanuel Aranas: Medico-legal officer who performed autopsy; found a single close-range gunshot wound on the victim’s forehead, muzzle within three inches, shooter and victim facing each other.
    • SPO1 Reynaldo Anclote: Investigating officer; took statements of Analie and Gregoria Reyes, but did not conduct crime-scene inspection.
    • Gregoria Reyes (victim’s mother): Learned of her son’s death from neighbor; incurred P10,000 funeral and P30,000 burial expenses; victim earned P800/day managing and driving two jeepneys.
    • Rogelio Fullente (neighbor): Heard knocking and a gunshot; saw appellant fire at Reyes, who fell; reported incident to victim’s parents.
  • Defense Evidence
    • Appellant’s Testimony: Claimed self-defense—entered room where wife and Reyes lay in underwear, struggle over victim’s gun ensued, gun discharged accidentally during grapple, killing Reyes.
    • No other defense witnesses.
  • Trial Court Judgment
    • The trial court credited Analie’s testimony, rejected self-defense, found appellant guilty of murder, sentenced him to reclusion perpetua, and awarded civil indemnity P50,000; actual damages P40,000; moral damages P20,000.

Issues:

  • Guilt and Validity of Conviction
    • Whether appellant was proven guilty beyond reasonable doubt of murder.
  • Qualifying Circumstances
    • Whether treachery and evident premeditation were sufficiently established.
  • Penalty and Damages
    • Proper classification of offense, applicable penalty range, and correct damage awards.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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