Case Summary (G.R. No. 242263)
Charges and Initial Testimonies
Aron and his brother, Franklin Anisco, were charged with homicide for Rolly's death resulting from a shooting incident on January 1, 2002. During the trial, witnesses from the prosecution, including Rolly's wife and brother, recounted the events leading up to the shooting. Testimonies indicated that Franklin pointed a gun at Rolly on stage during a New Year celebration, shot him, and then both Aron and Franklin fled the crime scene.
Investigative Developments
Following the shooting, Rolly was pronounced dead due to a gunshot wound as determined by Dr. Ma. Esperanza Gepillano, who conducted the autopsy. Aron voluntarily surrendered to the police and allegedly admitted to being involved in the incident. During the trial, both Aron and Franklin raised the defense of self-defense, claiming that the incident was accidental.
Ruling of the Regional Trial Court
On January 5, 2012, the RTC acquitted Franklin for lack of evidence but convicted Aron of homicide under Article 249 of the Revised Penal Code (RPC). The RTC imposed an indeterminate sentence and ordered Aron to pay actual, moral, and exemplary damages to Rolly's heirs. The court emphasized the failure of Aron to prove the elements of self-defense, highlighting that he did not demonstrate reasonable means to repel Rolly's alleged aggression.
Appeal to the Court of Appeals
Aron appealed the RTC's decision, but the CA affirmed the lower court's ruling with modifications regarding the monetary awards to the victim's heirs. The CA found no merit in Aron’s claims of the presence of self-defense, affirming the sufficiency of the prosecution's evidence establishing Aron's guilt beyond a reasonable doubt.
Petition for Review on Certiorari
Following the CA's decision, Aron filed a Petition for Review on Certiorari under Rule 45, arguing that the CA erred in affirming his conviction and dismissing his defenses without proper consideration. The Supreme Court reviewed the case under the framework of criminal appeals, stating that an appeal grants extensive review over the whole case, allowing for errors to be corrected even if not explicitly raised.
Supreme Court's Findings
The Supreme Court upheld the conviction for homicide, reaffirming that all elements required under Article 249 of the RPC were met in this case. It noted that self-defense was not applicable since Aron failed to convincingly demonstrate the requisite elements, such as acting in a lawful manner and the absence of intent to kill.
Elements of Homicide
To establish the crime of homicide, the following elements must be proven: (1) the death of a person occurred; (2) the accused committed the act without justifying circumstances; (3) intention to kill can be inferred; and (4) no qualifying circumstances that would elevate the crime to murder were present. The prosecution successfully established all these elements based on
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Case Overview
- This case involves a Petition for Review on Certiorari filed by Aron Anisco, challenging the Decision and Resolution of the Court of Appeals (CA) which affirmed with modification the conviction of Aron for the crime of Homicide.
- The case originated from the Regional Trial Court (RTC) of Roxas City, which convicted Aron of Homicide for the death of Rolly D. Apinan.
Antecedent Facts
- Aron and his brother, Franklin Anisco, were charged with Homicide for the death of Rolly D. Apinan, as per the Information dated March 8, 2002.
- The incident occurred on January 1, 2002, during New Year festivities at Sitio Luyo, Barangay Culasi, Roxas City.
- The prosecution's witnesses, including Rolly's wife and brother, testified that Franklin pointed a gun at Rolly and shot him, leading to Rolly's death from multiple gunshot wounds.
- After the shooting, Aron and Franklin fled the scene with the firearm used in the crime. Aron later voluntarily surrendered to the police.
- The autopsy performed by Dr. Ma. Esperanza Gepillano confirmed that Rolly died from a fatal gunshot wound.
Trial Proceedings
- During the trial, both Aron and Franklin pleaded not guilty. The defense claimed self-defense and presented witnesses to support their testimony.
- The RTC found Franklin not guilty due to lack of evidence but convicted Aron of Homicide, sentencing him to a prison term of six years and one day to twelve years and one day, alongside monetary damages to be paid to Rolly's hei