Title
People vs. Gutierrez y Dimaano
Case
G.R. No. 188602
Decision Date
Feb 4, 2010
Gutierrez convicted of murder and attempted murder after unprovoked shooting; self-defense claim dismissed due to lack of evidence and treachery established.
A

Case Summary (G.R. No. 188602)

Facts — Prosecution Version

On the evening of May 17, 2003, five persons (Regis, Marcelo, Gallemit, Boneo, Dalit) were conversing in front of Regis’s house in Makati. Appellant approached; when about two arm’s lengths away he allegedly suddenly raised his arm and shot Regis in the chest with a .45 caliber pistol. After Regis fell, appellant fired several more shots, wounding Dalit in the arm and firing at Boneo, Marcelo and Gallemit (the last three escaped without being hit). Appellant reportedly remained at the shooting location and later pursued Dalit but failed to catch him. The police arrived about twenty minutes later; Regis died that night and Dalit received medical treatment and surgery for his wound.

Facts — Appellant’s Version (Claim of Self-Defense)

Appellant testified that earlier he had been drinking and, while walking home, a group of five youths verbally confronted him and two advanced. He alleged he was boxed and beaten by one identified as Regis Ado; a gun then allegedly fell from Regis, which appellant grabbed. Appellant testified he was struck, fell, then, fearing further attack, fired the gun first at Regis and then toward the ground as a warning. He further claimed he fled afterward, discarded the firearm, and left the area.

Procedural History

Five separate informations were filed on August 15, 2003 charging the appellant with murder (Criminal Case No. 03-3639), frustrated murder (03-3640), and three counts of attempted murder (03-3641–03-3643). Appellant pleaded not guilty with counsel de oficio; trial ensued. The Regional Trial Court (Branch 62, Makati) rendered a decision on August 7, 2006 convicting appellant of murder, frustrated murder and three counts of attempted murder and imposing corresponding penalties and damages. The Appellant appealed to the Court of Appeals (CA), which on March 12, 2009 affirmed with modifications. The matter was subsequently elevated to the Supreme Court.

Issue on Appeal

The appellant’s principal challenge was that the trial court erred in convicting him because his guilt was not proven beyond reasonable doubt and because the trial court improperly relied on and credited the allegedly contradictory testimonies of prosecution eyewitnesses. The Office of the Solicitor General (OSG) urged affirmance with certain modifications: downgrading the count of frustrated murder (Dalit) to attempted murder, adjusting the award of actual damages, and seeking moral and exemplary damages for Regis’s heirs.

Trial Court Findings

The trial court rejected appellant’s claim of self-defense, credited the testimonies of the surviving victims as more credible than the appellant’s uncorroborated account, and found appellant guilty beyond reasonable doubt of murder (Regis), frustrated murder (Dalit), and attempted murder (Boneo, Marcelo, Gallemit). The RTC imposed reclusion perpetua for murder and terms for the other counts, and awarded actual damages, civil indemnity and other monetary reliefs as recited in its decision.

Court of Appeals Ruling

The CA affirmed the RTC decision but modified certain awards and the characterization of the Dalit injury. Specifically, the CA: (a) affirmed the murder conviction but reduced actual damages awarded to Regis’s heirs to P42,337.25 and added moral damages (P50,000), temperate damages (P10,000) and exemplary damages (P10,000); (b) modified the RTC’s finding of frustrated murder as to Dalit to attempted murder, sentencing accordingly; and (c) affirmed the attempted murder convictions for the other three complainants.

Supreme Court Analysis — Burden and Elements of Self-Defense

The Court reiterated the established three-element test for self-defense: (1) unlawful aggression on the part of the victim; (2) reasonable necessity of the means employed to repel it; and (3) lack of sufficient provocation by the person claiming self-defense. When an accused admits killing or wounding and pleads self-defense, the burden rests on the accused to prove these elements clearly and convincingly. The Court emphasized that unlawful aggression is the primary element and that self-defense cannot be sustained if not corroborated by independent, competent evidence or if the alibi is inherently doubtful. Applying these principles, the Court found appellant failed to discharge this burden: his testimony was uncorroborated, inconsistent with the eyewitnesses’ unanimous account that appellant fired suddenly without provocation, and thus the trial court’s credibility determination in favor of the prosecution witnesses was entitled to full respect.

Supreme Court Analysis — Treachery as Qualifying Circumstance and Conversion to Murder

The Court examined whether the fatal shooting of Regis was qualified by treachery. Treachery consists in a sudden, unexpected attack on unsuspecting victims that deprives them of any real chance to defend themselves. The evidentiary picture—sudden firing at close range, lack of provocation, and victims’ inability to defend themselves—supported the finding of treachery. Consequently, the killing was properly qualified as murder under Article 248 of the Revised Penal Code. Because no mitigating or aggravating circumstances were found to alter the penalty scheme, the indivisible penalty applicable for murder (reclusion perpetua) was affirmed pursuant to Article 63, paragraph 2 of the RPC.

Supreme Court Analysis — Nature of Injury to Dalit: Frustrated vs. Attempted Murder

The Court agreed with the CA’s modification regarding Dalit. The medical and factual proof did not establish that Dalit’s wound was sufficient in and of itself to cause death such that the accused had performed all acts of execution necessary to consummate murder. Where the wounds inflicted are not of a fatal nature, the proper classification is attempted murder rather than frustrated murder. Accordingly, the conviction was correctly reduced to attempted murder with the corresponding lesser penalty by two degrees under Article 51 of the RPC and the Indeterminate Sentence Law considerations applied by the CA were sustained.

Penalties and Application of the Indeterminate Sentence Law

  • Murder (Criminal Case No. 03-3639): reclusion perpetua (as imposed).
  • Attempted murder (Criminal Cases 03-3640 to 03-3643): two degrees lower than consummated felony, hence pena in prision mayor; under the Indeterminate Sentence Law the CA correctly set the minimum within prision correccional and the maximum within prision mayor in its medium period — specifically two years, four months and one day of prisi

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