Case Summary (G.R. No. 188751)
Facts
Bonifacio Nieva was charged with frustrated homicide due to an incident on October 28, 2005, in Malabon, Metro Manila, where he allegedly shot Judy Ignacio in the leg using a .357 caliber revolver. The charge stemmed from an argument regarding community issues, during which Nieva confronted Judy, drew his gun, and fired, hitting her. Medical testimony confirmed that her injury could have been fatal without timely medical intervention. The case proceeded to trial, where the RTC ultimately convicted Nieva of frustrated homicide, ruling that there were no qualifying circumstances for murder.
RTC Ruling
The RTC conviction of October 11, 2007, dictated that the absence of evident premeditation and treachery classified Nieva’s act as frustrated homicide rather than murder. Nieva was sentenced to six years and one day to twelve years of imprisonment, alongside damages for Judy's hospitalization expenses and moral damages. Nieva appealed the decision, arguing inconsistencies in witness testimony and asserting that the incident was accidental.
CA Ruling
On February 25, 2009, the Court of Appeals affirmed the RTC's ruling but moderated the penalty to a lesser range of four years and two months to eight years and one day of imprisonment. Nieva's Motion for Reconsideration was subsequently denied, leading him to file a petition for review.
Issues Presented
The central issue revolved around whether the Court of Appeals erred in affirming Nieva’s conviction for frustrated homicide, given his claims of witness inconsistencies and the possibility of accident as a defense.
Rulings on Witness Credibility
The Supreme Court upheld the trial courts' assessment of witness credibility, emphasizing that minor inconsistencies in testimony do not undermine the overall reliability of the witnesses. The identification of Nieva as the shooter was consistently corroborated across testimonies, which were deemed credible despite minor discrepancies regarding details of the shooting.
Defense of Accident
Nieva's claim that the shooting was unintentional was rejected by the Supreme Court, which noted that denial, absent substantial evidence, is an inherently weak defense. The Court cited that the him drawing a firearm in the midst of a quarrel was unlawful, and the repeated attempts to fire the weapon demonstrated intent, negating any defense of accident.
Intent to Kill
The Supreme Court ruled that the intent to kill was established beyond reasonable doubt, underscored by the use of a firearm and the nature of the inflicted wound. The Court clarified that a victim’s injury could
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Case Background
- This case pertains to a Petition for Review on Certiorari regarding the decision and resolution of the Court of Appeals (CA) confirming the conviction of Bonifacio Nieva for the crime of frustrated homicide.
- The initial decision was made on February 25, 2009, and the subsequent resolution on July 9, 2009.
Facts of the Case
- The Information, filed on November 2, 2005, charged Nieva with Frustrated Murder under Criminal Case No. 33415-MN, detailing an incident that occurred on October 28, 2005, in Malabon City.
- The accusation specified that Nieva, armed with a gun, attacked Judy Ignacio with the intent to kill, but she survived due to timely medical intervention.
Prosecution's Version
- The prosecution called five witnesses: Judy Ignacio (the victim), eyewitnesses Luna Ignacio and Raymundo Delatavo, attending physician Dr. Dindohope Serrano, and arresting officer PO2 Jesus Del Fiero.
- On the day of the incident, Nieva confronted Judy about a homeowners' association project and, after a heated exchange, drew a .357 caliber revolver.
- Despite his attempts to shoot, the gun jammed initially. However, after a struggle with Luna, the gun fired and hit Judy in her upper right leg, resulting in severe injuries that required medical attention.
- Dr. Serrano testified that Judy's injuries could have been fatal without prompt medical treatment.
Defense's Version
- The defense presented Nieva and two witnesses, although the latter's testimonies were deemed redundant.
- Nieva claimed the shooting was accidental, asserting that Luna had pointed the gun at him, and during the scuffle, it accidentally discharged.
- He insisted that there was