G.R. No. 137269 - People vs. Baldino

The case involves petitioners Benjamin Rustia, Jr., Benjamin Rustia, Sr., and Faustino “Bong” Rustia, charged in connection with the killing of Ambrocio Cristin.
The incident took place on June 14, 2008, at Barangay Malvar in Santiago City, Philippines, during a heated dispute over a piece of land.

The victim, Ambrocio Cristin, went to the Barangay Hall to meet with the accused regarding a land transaction.
An argument erupted at the hall due to disagreements concerning the land on sale, with escalated tempers on both sides.
Accounts by various eyewitnesses detailed that an altercation ensued, during which victim Cristin became involved in a physical confrontation with the accused.

During the dispute, Benjamin Rustia, Jr. is reported to have suddenly restrained Ambrocio Cristin by the waist while his co-accused, Benjamin Rustia, Sr. and Faustino Rustia, intervened by grappling with the victim’s arms.
Amid the struggle, Benjamin Rustia, Jr. managed to seize control of the victim’s gun, which was tucked in his waist.
After controlling the firearm, Benjamin Rustia, Jr. cocked and pointed the weapon at the victim and subsequently fired at least two shots.
Witnesses noted that the victim attempted to surrender by raising his hands and uttering words that indicated submission, yet was shot while in a defenseless position.

Following the shooting, the victim was transported to Flores Hospital and later to the De Vera Medical Center.
Medical evidence, notably from Dr. Jeffrey Demano, confirmed that the victim suffered a fatal gunshot wound—a wound entering at the anterior neck and exiting at the posterior area of the skull.
Ambrocio Cristin eventually died on June 24, 2008, as a consequence of the injuries sustained.

The Regional Trial Court (RTC) in Santiago City, on November 25, 2010, found Benjamin Rustia, Jr. guilty as a principal offender of murder qualified by treachery and his co-accused as accomplices.
The RTC imposed an indeterminate sentence on Benjamin, Jr. (reclusion temporal) and fixed lesser penalties on Benjamin, Sr. and Faustino Rustia (prision mayor range).
Civil liabilities were also imposed on the accused, including actual, death, moral, temperate, and exemplary damages payable to the victim’s family.
The Court of Appeals (CA) later affirmed the RTC decision with modifications, particularly adjusting the civil damages.

The petitioners contended that the amended information failed to allege specific factual circumstances constituting treachery.
They argued that the CA erred in characterizing the qualifying circumstance of treachery and in convicting Benjamin Rustia, Jr. of murder rather than homicide.
Additional issues raised included the alleged insufficiency in identifying the accomplices and the failure to consider incomplete self-defense as a mitigating circumstance.

Whether the means, method, or form of the attack—construed as treachery—was consciously and deliberately adopted by Benjamin Rustia, Jr. before the fatal shot.
Whether the evidence supports the qualification of the offense as murder (by treachery) rather than homicide, given the circumstances of the struggle and the shooting.
Whether the lower courts erred in their findings that established the presence of treachery based on the sudden and unexpected shooting after the victim had raised his hands in surrender.
Whether the self-defense claim, including the theory of incomplete self-defense based on the alleged reach for a firearm by the victim, was properly considered and supported by the evidence.
Whether Benjamin Rustia, Sr. and Faustino Rustia should be held liable as accomplices given the circumstances that indicate their participation during the grappling and subsequent events.