Case Summary (G.R. No. 265758)
Summary of Facts
Ybo Lastimosa was charged with Murder for the killing of Ildefonso Vega, Jr. on November 17, 2012, in Cansojong, Talisay City, Cebu. The Information alleged that Lastimosa deliberately attacked Vega with a firearm. After a trial where both the prosecution and defense presented their cases, the Regional Trial Court (RTC) initially convicted Lastimosa of Homicide, but the Court of Appeals (CA) later reversed this decision, convicting him of Murder, supported by a finding of treachery.
Prosecution's Evidence
The prosecution presented testimonies from witnesses who observed the incident. Elmer CaAeda testified that he saw Lastimosa shoot Vega three times while Vega was on his motorcycle, which corroborated with Vicente Cortes' observation from a distance. Dureza Vega, the victim's wife, testified to finding her husband already deceased upon arriving at the hospital. An autopsy determined the cause of death to be gunshot wounds.
Defense's Argument
Lastimosa, through his testimony and that of his partner Maria Amie Paquit, maintained an alibi, claiming he was at home during the incident. They argued that he had no motive to kill Vega and raised questions about the credibility of the prosecution’s witnesses, emphasizing that the prosecution failed to present an original death certificate, which they claimed undermined the case.
RTC's Ruling
The RTC found Lastimosa guilty of Homicide, noting that while the shooting incident was clear, treachery and evident premeditation were not established. The court based its decision on witness credibility and determined that the shooting did not happen in a manner that left Vega defenseless.
CA's Ruling
The CA, upon appeal, modified the RTC's ruling from Homicide to Murder, citing the presence of treachery in the manner in which the crime was committed. It held that Vega was in a position to defend himself and Lastimosa’s actions were sudden and without provocation, indicating a calculated attack. The appellate court also upheld the credibility of the prosecution witnesses despite contradictions raised by the defense.
Appeal and Arguments
Lastimosa appealed the CA's decision arguing that the prosecution had failed to prove guilt beyond a reasonable doubt, specifically questioning the admissibility of the photocopy of the death certificate. He also contended that the prosecution did not establish the qualifying circumstance of treachery, asserting that he believed the shooting could have occurred in a public setting where Vega was not entirely defenseless.
Court's Ruling
The Supreme Court affirmed the CA’s decision, noting that Last
...continue readingCase Syllabus (G.R. No. 265758)
Background and Procedural History
- Accused Ybo Lastimosa was charged with Murder for the fatal shooting of Ildefonso Vega, Jr. on November 17, 2012, in Talisay City, Cebu.
- Lastimosa pleaded not guilty at arraignment.
- The Regional Trial Court (RTC), Branch 12, Cebu City, initially convicted Lastimosa of Homicide and sentenced him to an indeterminate sentence.
- The Court of Appeals (CA) denied Lastimosa's appeal but modified his conviction from Homicide to Murder, sentencing him to reclusion perpetua.
- Lastimosa appealed to the Supreme Court raising errors on failure to prove guilt beyond reasonable doubt and the absence of treachery.
Facts of the Case
- On November 17, 2012, Lastimosa allegedly shot Ildefonso Vega, Jr. thrice while he was on his motorcycle near a cockpit in Sugarland, Cansojong, Talisay City.
- Eyewitnesses Elmer CaAeda and Vicente Cortes positively identified Lastimosa as the assailant.
- Ildefonso died instantaneously from gunshot wounds to the head and neck.
- The victim’s wife, Dureza Vega, found Ildefonso dead at the hospital.
- Autopsy was conducted and a death certificate was issued stating gunshot wounds as cause of death.
- Defense presented Lastimosa's alibi testimony supported by a live-in partner, asserting he was in Cebu City at the time.
Issue Presented
- Whether the conviction for Murder was proper despite the absence of the original death certificate and alleged defects in proving treachery and evident premeditation.
- Whether the testimonies and evidence presented by the prosecution are credible and sufficient.
Rulings of Lower Courts
- RTC found Lastimosa guilty of Homicide, noting that the killing was not attended by treachery or evident premeditation.
- CA found the appeal without merit, convicted Lastimosa of Murder, and applied the qualifying circumstance of treachery.
- CA ruled the photocopy of the death certificate as authentic and admissible, supporting the corpus delicti.
Key Evidence and Testimony
- Testimony of CaAeda: Close eyewitness account of Lastimosa shooting Ildefonso three times and subsequent escape.
- Testimony of Cortes: Corroborated shooting incident and identification of Lastimosa.
- Dureza’s testimony: Established the victim’s death and presented the death certificate (photocopy) during trial.
- Defense testimony: Lastimosa claims alibi and denial, asserting he was elsewhere.
- Photocopy of death certificate marked as Exhibit "B" without the original presented in court.
Issues on Evidence and Best Evidence Rule
- The prosecution relied on a photocopy of the death certificate, raising questions about its admissibility under the Best Evidence Rule.
- Historical development of the Best Evidence Rule in Philippine law was reviewed, tracing its evolution from the 1901 Code of Civil Procedure to the 2019 Revised Rules on Evidence.
- The 2019 Revised Rules on Evidence, effective May 1, 2020, allow duplicates of original documents, including paper-based duplicates such as photocopies, to be admissible unless authenticity is questioned or it would be unjust to admit the duplicate.
- The Rules on Electroni