G.R. No. 206768 - People vs. Castrodes

Petitioner Eladio C. Tangan was involved in an incident where a 29-year-old optometrist was fatally shot.
The incident occurred after a heated exchange, where the petitioner, drawing his firearm, discharged it resulting in the victim’s death.
The physical positioning during the incident was crucial: the medical examiner testified that the distance from the gun’s muzzle to the target was approximately 2 inches (but not more than 3 inches), and the gun was held almost perpendicular when fired, contradicting claims of an accidental discharge.

The manner and distance of the shot strongly disprove the petitioner’s claim of accidental shooting, given the inherent mechanism of a revolver which does not easily fire accidentally unless it is uncocked.
The physical evidence was regarded as a mute yet eloquent manifestation of the truth, ranking higher than testimonial evidence.

Eyewitnesses Rosalia dela Cruz and Mary Ann Borromeo testified that the petitioner took a gun from his car and fired it at the deceased.
The defense relied on a witness, Nelson Pante, whose statement was fraught with inconsistencies: the witness was 10 meters away with an obstructed view, his account of where the petitioner was hit varied from other evidence, and he failed to properly identify a third party allegedly involved in the altercation.

At trial, the petitioner did not raise an argument of self-defense. Instead, the lower courts noted the attendance of mitigating circumstances such as incomplete self-defense, sufficient provocation, and passion and obfuscation.
These mitigating circumstances were used by the trial court and affirmed by the Court of Appeals even though the petitioner argued their appreciation should have reduced his penalty.
The petitioner, in his subsequent motion for reconsideration, contended that these mitigating factors were not properly considered and that the penalty was substantially increased from a maximum of two years and four months (prision correccional) to a maximum of fourteen years, eight months, and one day (reclusion temporal).

Petitioner filed a Motion for Reconsideration invoking the rule that factual findings of the trial court and Court of Appeals are binding on the Supreme Court.
Alongside, an Omnibus Motion to Re-Raffle/Transfer and/or to Recuse was filed alleging bias on the part of the ponente, arguing that the Court’s departure from the lower courts’ findings demonstrated prejudicial disposition.
The petitioner contended that the modifications in penalty would expose him to reincarceration after having been already confined for over four years.

Whether the physical evidence and eyewitness testimonies sufficiently refute the petitioner’s claim of accidental shooting.
Whether the mitigating circumstances (such as incomplete self-defense, sufficient provocation, and passion and obfuscation) as identified by the trial court were properly appreciated and supported by the evidence.
Whether the elevation of the penalty from a maximum of two years and four months of prision correccional to a maximum of fourteen years, eight months, and one day of reclusion temporal is justified based on the factual findings.
Whether the petitioner’s Motion for Reconsideration and the Omnibus Motion alleging bias have merit given the clear evidentiary record and lower courts’ findings.
Whether the conflicting and inconsistent testimony of the petitioner’s defense witness undermines the claim of self-defense.