Title
Source: Supreme Court
Cabuslay vs. People
Case
G.R. No. 129875
Decision Date
Sep 30, 2005
A police officer shot and killed an unarmed collector, claiming self-defense; the Supreme Court convicted him of homicide, rejecting his claims as unsubstantiated.

Case Summary (G.R. No. 129875)

Applicable Law

The relevant law for the case is based on the Revised Penal Code of the Philippines, particularly concerning homicide and self-defense principles.

Background of the Incident

On August 5, 1992, Paquito Umas-as, a payment collector on a motorcycle, encountered a mobile checkpoint established by the aforementioned police officers in Kauswagan, Lanao del Norte. Witness testimony indicated that when Umas-as was asked to show his identification, he was shot by Cabuslay, resulting in his death.

Prosecution Evidence

The prosecution presented multiple witnesses, including Dr. Tammy Uy and forensic chemist Bernabe P. Arenga, to establish the circumstances surrounding Umas-as's death, which was attributed to multiple gunshot wounds. The evidence included the absence of gunpowder nitrates on Umas-as’s hands, suggesting he did not fire a gun during the encounter.

Defense Arguments

In contrast, the defense argued that Cabuslay acted in self-defense after Umas-as allegedly threatened to shoot Cabuslay and his superior, Celso Regencia. Witnesses from the defense attempted to corroborate this claim, citing an intelligence report of an assassination plot against local officials as the justification for the police's aggressive actions during the checkpoint operation.

Sandiganbayan's Findings

The Sandiganbayan found Cabuslay guilty of homicide, rejecting the defense's self-defense claim. The court highlighted several deficiencies in the defense's arguments, particularly the lack of physical evidence such as the handgun alleged to have been used by Umas-as, and the inconsistency in the defense's testimonies.

Self-Defense Evaluation

For Cabuslay's self-defense claim to hold, he needed to prove unlawful aggression from Umas-as, which the Sandiganbayan determined was not present. The court ruled that the evidence presented did not demonstrate a legitimate threat from Umas-as that would justify the use of deadly force.

Assessment of Credibility

The testimony of the prosecution’s witness, Zaragosa, was deemed credible and consistent, providing a significant basis for the conviction. The court found no evidence that Zaragosa had a motive to fabricate his account of the shooting.

Civi

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