Case Summary (G.R. No. 149152)
Factual Background
On September 12, 1994, Mamangun was charged with Murder for the shooting of Gener Contreras, allegedly occurring on July 31, 1992, while responding to a reported robbery. Mamangun entered a plea of "Not Guilty" and proceeded to a trial where both prosecution and defense presented eyewitness testimonies and forensic evidence regarding the incident.
Incident Overview
During the evening of the incident, Mamangun and fellow officers responded to a reported robbery-holdup. After obtaining permission from a homeowner, they proceeded to a rooftop where they encountered a man they believed to be the suspect. Mamangun, leading the group, fired his weapon, fatally striking Contreras, who was misidentified as the suspect. The autopsy indicated that Contreras died from multiple gunshot wounds.
Testimonies Presented
The prosecution's case was supported by eyewitness Crisanto Ayson, who claimed to have witnessed the shooting and described Mamangun firing upon Contreras, who was pleading his innocence. The defense presented a different narrative, asserting that Mamangun shot Contreras in self-defense after the latter allegedly threatened him with a steel pipe.
Sandiganbayan's Decision
On January 19, 2001, the Sandiganbayan convicted Mamangun of Homicide, ruling that although he acted in the performance of his duty, his actions were not justified under the law. The court did not find sufficient aggravating circumstances to classify the act as Murder but acknowledged the privileged mitigating circumstance of incomplete justification due to Mamangun's role as a police officer.
Legal Standards and Self-Defense Claim
The petitioner contended that the shooting was justified under Article 11 of the Revised Penal Code as it was done in the performance of his duties. However, the Court did not accept this argument, concluding that self-defense was not established due to the absence of unlawful aggression from Contreras at the time of the shooting.
Assessment of Credibility
The Court deemed the defense's claim of self-defense self-serving and found inconsistencies
...continue readingCase Syllabus (G.R. No. 149152)
Case Overview
- The case involves a petition for review under Rule 45 of the Rules of Court filed by Rufino S. Mamangun, a police officer, challenging a decision of the Sandiganbayan convicting him of Homicide.
- The conviction arose from an incident on July 31, 1992, where Mamangun shot and killed Gener M. Contreras, mistakenly believing him to be a robbery suspect.
Factual Background
- Incident Date: July 31, 1992
- Location: Barangay Calvario, Meycauayan, Bulacan, Philippines
- Role of the Petitioner: Rufino Mamangun was on duty as a Police Officer (PO2) responding to a reported robbery-holdup.
- Events Leading to the Shooting:
- Liberty Contreras shouted "Magnanakaw... Magnanakaw," prompting residents to pursue a suspect.
- Mamangun and fellow police officers were dispatched to the scene where they believed the suspect had fled.
- Upon reaching the rooftop of Antonio Abacan's house, Mamangun shot a man he thought was the suspect, who was later identified as Gener Contreras.
Trial Proceedings
- Charges: Mamangun was initially charged with Murder, which was later reduced to Homicide.
- Prosecution Evidence:
- Eyewitness testimony from Crisanto Ayson, who claimed to have seen Mamangun shoot Contreras after recognizing him.
- Autopsy conducted by Dr. Benito Caballero confirmed Contreras died from multiple gunshot wounds.
- Defense Evidence:
- Mamangun and his fellow officers presented a narrative suggesting Contreras attacked Mamangun with a steel pipe, justifying the shooting as self-defense.
- They denied the presence of the p