Case Summary (G.R. No. 224900)
Charges and Initial Proceedings
Bugarin was charged with two counts of murder (Criminal Case Nos. CBU-83610 and CBU-83611) and one count of attempted murder (Criminal Case No. CBU-83613). The charges stemmed from the alleged shootings of Esmeraldo and Cristito Pontanar, resulting in their deaths, and the attempted shooting of Maria Glen Neis Pontanar. Bugarin pleaded not guilty and claimed self-defense.
Factual Background
Bugarin contended that his actions were defensive, prompted by an altercation between his wife Anecita and Esmeraldo, who was allegedly armed. In contrast, the prosecution portrayed Bugarin as the aggressor, detailing a scenario where he opened fire on Esmeraldo, followed by Cristito's attempted intervention, and subsequently shooting Maria Glen.
Trial Court Decision
On July 5, 2012, the RTC convicted Bugarin of double murder and attempted murder, noting the special aggravating circumstance of using an unlicensed firearm. The RTC sentenced him to reclusion perpetua for each murder charge and imposed various damages.
Court of Appeals Review
Bugarin appealed the RTC’s decision. On July 31, 2015, the Court of Appeals affirmed the RTC's ruling with modifications, reducing one charge from murder to homicide and altering penalties and damages awarded to the victims' heirs.
Appeal to the Supreme Court
Bugarin further appealed to the Supreme Court, maintaining his claim of innocence and asserting that he acted in self-defense. The Court reiterated the necessity for the accused to prove self-defense with clear and convincing evidence, particularly regarding the existence of unlawful aggression from the victims.
Burden of Proof and Self-Defense
The Supreme Court emphasized that the burden to demonstrate self-defense falls on the accused once he admits to inflicting harm. Bugarin failed to adequately prove that he faced unlawful aggression, which is essential for a self-defense claim. The Court found his testimony to lack credibility when compared to that of Maria Glen, the surviving victim.
Evaluating Treachery
The Court addressed the issue of treachery, noting that Bugarin’s sudden gunfire on Esmeraldo deprived him of the chance to defend himself. The qualifications for treachery were also evaluated concerning Cristito and Maria Glen, leading the Court to uphold the characterization of Bugarin's actions as treacherous.
Modifications on Senten
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Case Background
- The case involves the appeal of Nestor M. Bugarin against the Decision dated July 31, 2015, of the Court of Appeals (CA) in CA-G.R. CEB-CR-HC No. 01530.
- The CA had affirmed and modified the Joint Judgment of the Regional Trial Court (RTC) of Cebu City, which found Bugarin guilty beyond reasonable doubt of double murder and attempted murder in Criminal Case Nos. CBU-83610, CBU-83611, and CBU-83613.
Charges Filed
Criminal Case No. CBU-83610 (Murder)
- Bugarin allegedly shot Esmeraldo B. Pontanar multiple times, causing his death due to multiple gunshot wounds.
Criminal Case No. CBU-83611 (Murder)
- Bugarin shot Cristito C. Pontanar, the 72-year-old father-in-law, when Cristito attempted to intervene in the attack on Esmeraldo, resulting in Cristito's death.
Criminal Case No. CBU-83613 (Attempted Murder)
- Bugarin attempted to shoot Maria Glen Neis Pontanar, inflicting a gunshot wound to her thigh but failed to complete the act of murder.
Arraignment and Plea
- Bugarin pleaded not guilty to all charges, admitting to the shootings but claiming self-defense.
- A reverse trial ensued as per Section 11(e), Rule 119 of the Rules of Court.
Factual and Procedural Antecedents
- Bugarin contended that he acted in self-defense during an altercation involving his wife and the Pontanars.
- He claimed Esmeraldo was armed with multiple firearms and initiated the confrontation.
- The prosecution presented evidence of long-standing animosity between the Bugarins and Pontanars.
Trial Court's Findings
- The RTC convicted Bugarin of double murder and attempted murder, considering the use of an unlicensed firearm as a special ag