Case Summary (G.R. No. 236269)
Applicable Law
The relevant legal framework includes the Revised Penal Code of the Philippines, which outlines murder and homicide penalties, and the Indeterminate Sentence Law. Given the case's decision date, the 1987 Philippine Constitution governs the review procedure.
Procedural History
Upon arraignment, Feliciano entered a not guilty plea to the murder charges. The trial involved multiple witnesses, including fellow police officers and a physician who provided evidence regarding the victims' deaths and the circumstances leading to the alleged homicides.
Facts of the Case
On the night of the incident, after an altercation with SPO4 Santiago Miguel, Feliciano allegedly returned to the police station armed and initiated a shooting spree that resulted in the deaths of P/Inspector Miguel and PO3 Arabejo, while SPO4 Miguel died due to his injuries from the encounter with Feliciano. Evidence was presented including eyewitness accounts of the confrontation, the firearms involved, and forensic examinations.
Prosecution's Evidence
The prosecution provided numerous eyewitness testimonies. Key witnesses described sporadic conflicts between Feliciano and the victims prior to the shooting. Forensic evidence, including ballistic tests, confirmed that the firearms used in the killings were registered to the involved parties. Medical examinations established the causes of death for each victim, attributing them to multiple gunshot wounds.
Defense's Claim
Feliciano's defense centered on the argument of passion and obfuscation, contending that he was provoked by the verbal assault from SPO4 Miguel. He claimed that upon returning to the station, he did not premeditate the killings, and that he mistakenly identified P/Inspector Miguel as his targeted assailant during the altercation.
Trial Court's Findings
The trial court convicted Feliciano of murder for the deaths of P/Inspector Miguel and PO3 Arabejo and sentenced him to death, while he received a lesser sentence for the killing of SPO4 Miguel, due to mitigating circumstances.
Appellate Review
Feliciano appealed, arguing that the killings lacked the qualifying circumstances of treachery and evident premeditation, which the trial court determined were present. The Office of the Solicitor General countered that the sudden nature of the attack on both P/Inspector Miguel and PO3 Arabejo reflected treachery.
Supreme Court's Ruling
The Supreme Court conducted an extensive review of the circumstances surrounding the killings. It found that the prosecution met its burden of proof regarding the murder charge against P/Inspector Miguel but erred in the application of treachery regarding PO3 Arabejo's killing. The Court determined that sufficient provocation affected Feliciano's state of mind, thereby mitigating his liability.
Penalty Assessment
The Supreme Court determined that the death penalty was not warranted for PO3 Arabejo, concluding that the circumstances substantiate a conviction of homicide instead of murder.
...continue readingCase Syllabus (G.R. No. 236269)
Case Overview
- The case involves PO3 Noel Feliciano, who was accused of three counts of murder of fellow police officers, specifically P/Inspector Edgardo L. Miguel, PO3 Roberto Arabejo, and SPO4 Santiago Miguel.
- The Regional Trial Court of Isabela, Basilan, found him guilty in Criminal Cases Nos. 2211-142 and 2213-145, imposing the death penalty, and in Criminal Case No. 2214-146, sentencing him to an indeterminate prison term.
- The case is under automatic review due to the imposition of the death penalty.
Background of the Incident
- The murders occurred on September 29, 1994, at the Isabela Police Station in Basilan, where Feliciano was involved in a verbal altercation with SPO4 Santiago Miguel, leading to a series of violent events.
- The confrontation escalated, resulting in Feliciano retrieving firearms and ultimately shooting his fellow officers.
Prosecution Witnesses and Testimonies
- SPO3 Rupe Hupida: Witnessed the altercation and the shooting; testified that he saw Feliciano shoot Inspector Miguel and later attempt to shoot others.
- SPO1 Danilo Lubaton: Confirmed Hupida's account and reported seeing Feliciano surrender after the incident.
- PO3 Wilfrido Arguelles: Testified about the atmosphere in the station and observed Feliciano aiming firearms during the incident.
- SPO4 Vicente Alcayra: Overheard the argument and saw the aftermath, assisting the wounded officers.
- Dr. Joseph Guevarra: Provided autopsy results confirming the ca