Case Summary (G.R. No. 202867)

Case Overview

• The case involves an appeal by Regie Labiaga against the Decision of the Court of Appeals-Cebu, which affirmed his conviction for murder and frustrated murder.
• The Regional Trial Court (RTC) had previously convicted Labiaga in two separate criminal cases related to a shooting incident on December 23, 2000.

Facts of the Case

• Labiaga, along with co-accused Balatong Barcenas and Cristy Demapanag, was charged with murder and frustrated murder.
• The murder charge stemmed from the shooting of Judy Conde, resulting in her death, while the frustrated murder charge involved the shooting of Gregorio Conde, who survived due to timely medical intervention.
• Both Labiaga and Demapanag pleaded not guilty, leading to a joint trial.

Prosecution's Version

• The prosecution presented witnesses, including Gregorio Conde and medical professionals, who testified about the events of the shooting.
• The prosecution's narrative indicated that Labiaga shot Gregorio Conde first and then shot Judy Conde when she came to assist her father.
• Judy was pronounced dead upon arrival at the hospital, while Gregorio sustained a non-fatal gunshot wound.

Defense's Version

• Labiaga admitted to being present during the incident but claimed self-defense, alleging that Gregorio attacked him with a shotgun.
• Demapanag provided an alibi, stating he was far from the crime scene at the time of the shooting.

Ruling of the RTC

• The RTC acquitted Demapanag due to insufficient evidence but convicted Labiaga of both murder and frustrated murder.
• Labiaga was sentenced to reclusion perpetua for murder and a prison term for frustrated murder, along with civil indemnity to the victims' heirs.

Ruling of the CA-Cebu

• Labiaga appealed the RTC's decision, arguing that the prosecution failed to prove his guilt beyond a reasonable doubt.
• The CA-Cebu upheld the RTC's convictions but modified the decision to include moral and exemplary damages.

Court's Review and Findings

• The Court found Labiaga guilty of murder and modified the conviction for frustrated murder to attempted murder.
• The Court rejected Labiaga's self-defense claim, emphasizing the lack of corroborating evidence and the credibility of the prosecution's witnesses.

Legal Principles on Self-Defense

• The burden of proof shifts to the accused when claiming self-defense, requiring clear and convincing evidence.
• The Court noted that Labiaga's self-serving assertions were insufficient against the positive identification of witnesses.

Treachery and Its Implications

• The Court affirmed the appreciation of treachery in the attack, as the victims were unarmed and did not have a chance to defend themselves.
• The use of a shotgun against unarmed individuals was deemed treacherous.

Distinction Between Attempted and Frustrated Murder

• The Court clarified the definitions of attempted and frustrated felonies, concluding that Labiaga's actions constituted attempted murder due to the non-fatal nature of Gregorio's injuries.
• The Court emphasized that the absence of evidence showing the wound was mortal led to the classification of the crime as attempted murder.

Damages Awarded

• The Court increased...continue reading