Case Summary (G.R. No. 179487)
Factual Findings
During the gathering, a conflict occurred between the petitioner and one Joey Gaton, leading to a physical altercation where the petitioner fatally shot Gaton in the abdomen with a .45 caliber pistol. The incident prompted the filing of an Information for murder against the petitioner, alleging intent to kill, treachery, and evident premeditation.
Proceedings and Arraignment
Upon his arraignment on March 18, 2002, the petitioner pleaded not guilty. The prosecution's case rested on eyewitness testimony from the victim's brother, Gabriel Gaton, and two neighbors. Their testimonies directly implicated the petitioner as the gunman, while the defense claimed someone else was the assailant, supported by a forensic chemist's testimony that the petitioner tested negative for gunpowder residue.
Decision of the Regional Trial Court (RTC)
On June 14, 2005, the RTC found the petitioner guilty of homicide rather than murder, citing a lack of sufficient proof for treachery and evident premeditation. He was sentenced to an indeterminate period of imprisonment, along with a requirement to compensate the victim's heirs.
Appeal to the Court of Appeals (CA)
In an appeal to the CA, the petitioner challenged the credibility of the prosecution witnesses, questioning their motives due to familial ties with the victim. The CA upheld the RTC's decision but modified the actual damages awarded and the maximum term of the petitioner’s sentence.
Supreme Court's Ruling
The Supreme Court affirmed the CA's decision, backing the findings of the lower courts. The Court held that the trial court's evaluation of witness credibility should be given deference, particularly when upheld by the appellate court. The testimonies of the three eyewitnesses were determined credible and compelling enough to establish the petitioner's guilt beyond reasonable doubt.
Testimony Analysis
The testimonies reflected clear accounts of the event, with witnesses recalling specific details about the attack leading to Gaton's death. The Court determined the familial relationship of the witnesses to the victim did not undermine their credibility, emphasizing that close relations may enhance a witness's reliability.
Consideration of the Paraffin Test
The Court dismissed the relevance of the negative paraffin test results for the petitioner, citing that such tests are not conclusive proof of a person's actions at the time but can only suggest the possibility of gun use. The Court reiterated existing legal precedents that deem such tests as unreliable for establishing firearm d
...continue readingCase Syllabus (G.R. No. 179487)
Case Overview
- This case involves a Petition for Review on Certiorari under Rule 45, challenging the August 23, 2007 Decision of the Court of Appeals (CA) in CA-G.R. CR No. 29937.
- The CA affirmed with modification the June 14, 2005 decision of the Regional Trial Court (RTC) of Quezon City, Branch 81, which found petitioner Romeo Ilisan guilty beyond reasonable doubt of homicide.
Factual Background
- The incident occurred on February 3, 2002, during a baptismal celebration at Ricky Silva's residence in Barangay Nagkaisang Nayon, Novaliches, Quezon City.
- Petitioner Romeo Ilisan and Joey Gaton were in different groups during the celebration; a conflict arose when one of Ilisan's companions was offended by Gaton's gaze.
- An ensuing melee resulted in Ilisan shooting Gaton in the abdomen, leading to Gaton's immediate death.
- The firearm used was a .45 caliber pistol.
Charges and Arraignment
- On February 7, 2002, an Information for murder was filed against Ilisan.
- The charge specified that Ilisan acted willfully and unlawfully with intent to kill, treachery, evident premeditation, and the use of superior strength.
- Ilisan pleaded not guilty when arraigned on March 18, 2002.
Evidence Presented
- The prosecution's case relied on testimonies from three witnesses: Gabriel Gaton (the victim's brother), Marlon Dellamas, and Edgardo Dag-um, all of whom positively identified Ilisan as the gunman.
- The defense claimed that another guest, Chito Partisa