Case Summary (G.R. No. 128900)
Background of the Incident
On the morning of November 2, 1996, a cordial game of cards between Antonio and Tuadles escalated into a violent confrontation. The prosecution argued that Antonio shot Tuadles with premeditated intent through treachery after a dispute regarding their card game.
Trial Court Decision
The Regional Trial Court of Pasig City found Antonio guilty of murder, characterized by treachery, and sentenced him to reclusion perpetua. Nieto and Cartalla were found guilty as accessories and received lesser penalties. The trial court ordered monetary compensation to be paid to the heirs of Tuadles.
Appeal by Accused
Antonio appealed the decision on several grounds, questioning the credibility of the sole prosecution eyewitness, SG Jose Jimmy Bobis, and contending the absence of treachery and provocation. Nieto and Cartalla also filed their appeals, claiming misjudgment regarding their convictions.
Eyewitness Testimony
SG Bobis initially provided a statement that contradicted his later testimony. However, the trial court deemed his in-court testimony credible despite the inconsistencies, affirming the brutal and instant nature of the shooting which left Tuadles no chance to defend himself.
Self-Defense Claim
Antonio claimed that he acted in self-defense, asserting that Tuadles attempted to take his gun during a heated argument. The court pointed out that self-defense requires proof of unlawful aggression, which was not substantiated, as there was no concrete evidence that Tuadles posed an imminent threat.
Treachery
Treachery, as insisted by the prosecution, was established by proving that Antonio employed means to execute the crime without risk to himself. The defense argued that the altercation preceding the shooting did not provide Tuadles a chance for self-defense, but the court found that the emotional state during the brief exchange negated premeditated plans.
Conclusion of the Ruling
The appellate court upheld that treachery was not established, thus reducing Antonio's conviction from murder to homicide and altering his sentence accordingly. Nieto’s conviction as an accessory was affirmed based on his failure to perform his duty as a police officer. Conversely, Cartalla was acquitted as the prosecution failed to sub
...continue readingCase Syllabus (G.R. No. 128900)
Case Overview
- The case involves an appeal from the Decision dated April 30, 1997, rendered by the Regional Trial Court of Pasig City, Branch 156.
- The primary charge is murder against Alberto S. Antonio, while SPO4 Juanito N. Nieto and SPO1 Honorio Cartalla, Jr. were charged as accessories.
- The trial court found all three accused guilty, imposing penalties and civil liabilities.
Facts of the Case
- On November 2, 1996, a card game between friends Alberto S. Antonio and Arnulfo "Arnie" Tuadles turned deadly when Antonio shot Tuadles in the forehead with a .9mm Beretta pistol.
- The shooting occurred after an argument over scores in their game of "apusoy dosa" at the International Business Club in San Juan, Metro Manila.
- Witnesses, including security guard Jose Jimmy Bobis, provided conflicting testimonies about the events leading up to the shooting.
Background of the Parties
- Alberto S. Antonio was a former chairman of the Games and Amusement Board and had a social acquaintance with the victim, Arnulfo Tuadles, a former professional basketball player.
- The two men had recently reconnected through their shared interest in card games at the IBC.
Incident Description
- The argument started just before breakfast when Antonio and Tuadles were settling their game scores.
- Prosecution claimed that Antonio shot Tuadles without warning; defense claimed it was an accidental shooting during a struggle over the gun.
- Bobis, the prosecution's key eyewitness, initially stated he did not see the shooting but later testified he witnessed Antonio pull the gun and shoot Tuadles.
Trial Court Findings
- The trial court found Antonio guilty of murder, qualifying the killing by treachery due to the sudden nature of the attack that afforded Tuadles no opportunity for self-defense.
- Nieto and Cartalla