Case Summary (G.R. No. 130397)
Charges and Proceedings
Diego and Galvez faced charges of murder and double frustrated murder in the Quezon City Regional Trial Court, following a transfer of venue from Malolos after initial charges of homicide were filed. The core accusations stemmed from an event on November 11, 1993, where Diego and Galvez allegedly shot the Vinculado family, resulting in Alvin's death and injuries to Miguel and Levi.
Factual Background
On the day of the incident, Miguel Vinculado, accompanied by his nephews Levi and Alvin, confronted Mayor Galvez about the expropriation of his land for road construction. After a heated exchange, Mayor Galvez drew a gun and attempted to take the Vinculados' cameras. A violent altercation ensued, during which Galvez allegedly shot Miguel, while Diego used a rifle to shoot both Levi and Alvin, resulting in fatal and serious injuries.
Defense Claims
Diego's defense hinged on claims of self-defense and defense of a stranger, arguing that he acted to protect Mayor Galvez and himself from the perceived illegal aggression of the Vinculados, whom he claimed were armed. However, this assertion relied heavily on Diego's interpretation of the events leading up to the shooting, which included no corroborating evidence supporting his claims of imminent danger.
Assessment of Self-Defense
For a self-defense claim to be valid under Philippine law, the accused must prove (1) unlawful aggression from the victim, (2) the means employed to repel such aggression were reasonable, and (3) there must be no provocation from the person defending. The trial court found that Diego's account lacked these elements, concluding that there was no unlawful aggression from the Vinculados and that the alleged weapons (a knife and a revolver) were never recovered.
Court Findings
The trial court determined that the evidence presented did not support Diego's assertions, particularly citing the lack of any physical evidence confirming the presence of the weapons he claimed were used against him. Furthermore, the court highlighted Diego's evasive actions post-event, including fleeing and hiding, as inconsistent with a claim of legitimate self-defense.
Judgment and Sentencing
The trial court found Diego guilty of murder and double frustrated murder, considering the mitigating circumstance of voluntary surrender. He was sentenced to reclusion pe
...continue readingCase Syllabus (G.R. No. 130397)
Case Overview
- Court: Supreme Court of the Philippines
- Division: First Division
- G.R. No.: 130397
- Date: January 17, 2002
- Plaintiff: People of the Philippines
- Defendants: Honorato Galvez, Godofredo Diego, and John Doe
- Nature of Charges: Homicide and frustrated homicide, later elevated to murder and frustrated murder.
Procedural History
- Initially charged with homicide and two counts of frustrated homicide in Bulacan.
- Venue transferred to Quezon City Regional Trial Court where charges were upgraded.
- Additional charge against Galvez for illegal firearm possession.
Charges Against Accused
Murder (Criminal Case No. Q-94-55484):
- Date: November 11, 1993
- Victim: Alvin Vinculado
- Circumstances: Conspiracy involving armed attack resulting in death.
Frustrated Murder (Criminal Case No. Q-94-55485):
- Victim: Miguel Vinculado Jr.
- Gunshot wounds inflicted but survived due to medical intervention.
Frustrated Murder (Criminal Case No. Q-94-55486):
- Victim: Levi Vinculado
- Similar circumstances as above, injury sustained but survived.
Factual Background
- On the morning of November 11, 1993, Godofredo Diego informed Miguel Vinculado about the cutting down of coconut trees due to a road widening project.
- Miguel and his nephews confronted Mayor Galvez regarding the removal of trees, leading to a heated exchange.
- Cameras were seized during the confrontation, escalating tensions.
- Gunfire ensued, resulting in the deaths and injuries of several Vinculados.
Testimonies and Claims
- Godofredo D