G.R. No. 185206 - People vs. Aguilar

Virgilio Talampas y Matic, the petitioner, was convicted for homicide by the Regional Trial Court (RTC), Branch 25 in BiAan, Laguna, for the killing of Ernesto Matic y Masinloc.
Talampas subsequently appealed the RTC’s decision before the Court of Appeals (CA), which affirmed his conviction.
On November 23, 2011, the petition for review on certiorari was filed, seeking to overturn the lower courts’ findings and the imposed sentence.

On or about July 5, 1995, in BiAan, Laguna, Talampas allegedly attacked using a short firearm while on a bicycle.
The information, dated November 17, 1995, stated that Talampas attacked with intent to kill and without justifiable cause, shooting Ernesto in the back which caused his instantaneous death.
The incident was described as a willful, unlawful, and felonious act causing injury and death, adversely affecting the victim’s surviving heirs.

Jose Sevillo testified that he witnessed Talampas riding a bicycle, dismounting, brandishing a short gun, and firing multiple shots.
Sevillo recounted that Talampas fired at Eduardo Matic first, followed by firing at Ernesto, with the latter shot proving fatal.
Additional testimony by Jose included details about the sequence of events and his sworn statement executed at the BiAan Police Station.

Francisco Matic provided background on the victim, Ernesto, describing his occupation and income sources.
Jerico Matic, son of Ernesto, testified on the emotional and financial impact of his father’s death on the family.
Dr. Valentin Bernales, who performed the autopsy, confirmed that a gunshot wound to the back in a vital area was the cause of death.
Josephine Matic, the wife of Ernesto, detailed the hardships her family faced following the incident.

Talampas claimed self-defense, contending that his real target was Eduardo Matic who had allegedly assaulted him with a monkey wrench.
He further argued that during a struggle over control of the revolver, the weapon accidentally discharged, injuring and eventually killing Ernesto.
Talampas also interposed an accident defense, asserting the unintended nature of the fatal shot.

The RTC rejected Talampas’ pleas of self-defense and accident.
It found him guilty beyond reasonable doubt of homicide and imposed an indeterminate penalty of imprisonment ranging from 10 years and 1 day (prision mayor) to 14 years and 8 months (reclusion temporal), along with the award of various damages to the victim’s heirs.

The CA affirmed the RTC’s findings, holding that by invoking self-defense, Talampas effectively admitted to the killing.
The court ruled that the evidence did not meet the burden required for a self-defense claim and that the accident defense did not exonerate Talampas, given the deliberate nature of his actions.
Additionally, the CA adjusted the damage awards by deleting the award for temperate damages on the ground that it was mutually exclusive with the actual damages awarded.

Whether the evidence presented was adequate to establish Talampas’ guilt beyond reasonable doubt in the killing of Ernesto Matic.
Whether the sequence of events, as testified primarily by eyewitnesses, was sufficient to eliminate any reasonable doubt regarding his culpability.

Whether the invocation of self-defense was correctly rejected, given that his actions did not involve repelling an unlawful aggression from the victim.
Whether the claim of accidental death was tenable considering the nature of Talampas’ actions and the ensuing outcome.

Whether the imposition of an indeterminate sentence, with a minimum of 10 years and 1 day and a maximum of 14 years and 8 months, was in conformity with the provisions of the Revised Penal Code and the Indeterminate Sentence Law.
Whether the computation of the maximum term needed adjustment, specifically with respect to the one-day increment based on legal mandates from the Indeterminate Sentence Law.