Title
Supreme Court
People vs. Borreros
Case
G.R. No. 125185
Decision Date
May 5, 1999
Borreros convicted of Murder and Homicide for shooting two victims at a mahjongan; self-defense rejected, treachery affirmed, civil indemnity upheld.

Case Summary (G.R. No. 125185)

Case Background and Proceedings

On June 26, 1991, Assistant City Prosecutor Mercedes D. Penamora filed an Information against Borreros, charging him with murder and homicide for the deaths of Medina and Almario, respectively. The prosecution presented several witnesses, including Arturo Ibarrientos and Faustino Varona, who testified that Borreros attacked the victims with a handgun, resulting in their deaths. During his arraignment on May 11, 1994, Borreros entered a negative plea, leading to a trial where he presented a self-defense narrative, supported by other witnesses who corroborated aspects of his account.

Trial Court's Decision

The trial court found Borreros guilty of murder, qualifying the killing of Medina by treachery, and guilty of homicide concerning Almario, as there were no mitigating circumstances. Borreros was sentenced to reclusion perpetua for Medina's death and received an indeterminate sentence concerning Almario, alongside civil indemnity payments to the families of both victims.

Borreros' Arguments on Appeal

Borreros challenged the trial court's decision, arguing that it erred by not considering his self-defense claim, misapplying the concept of treachery, and improperly ordering him to pay civil indemnities for both victims. He asserted that the circumstances of the altercation justified his actions.

Court's Analysis on Self-Defense

The appellate court dismissed Borreros' self-defense argument, emphasizing his burden to prove unlawful aggression from the victims, the necessity of his response, and that he acted without sufficient provocation. The court found that the evidence did not establish such aggression. Borreros claimed he was attacked by Medina, but his own testimony indicated that the confrontation had de-escalated after he disarmed Medina, negating unlawful aggression at the time he shot Medina.

Findings on Treachery

The court confirmed the trial court's finding of treachery in Medina's killing, noting the element of surprise in Borreros' attack when Medina was caught off guard. The testimonies of prosecution witnesses supported that Borreros shot Medina without warning. In contrast, for Almario's killing, the court found insufficient evidence to classify the act as treacherous due to the absence of detailed accounts regarding how Almario was

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