Case Summary (G.R. No. 127753)
Legal Indictments
The accuser was indicted for two crimes:
- Murder (Criminal Case No. U-8719) - Accused shot the victim, resulting in his death, constituting murder under Article 248 of the Revised Penal Code.
- Illegal Possession of Firearms and Ammunition (Criminal Case No. U-8720) - The accused was found in possession of an unlicensed firearm, which he used to commit the murder, violating Presidential Decree No. 1866.
Factual Background
On the evening of the incident, Marcelo Valdez was conversing with his son, the victim, in their nipa house when two consecutive gunshots were fired from outside. The victim was shot twice, suffering fatal wounds, and identified the appellant as his assailant before succumbing to his injuries. The appellant fled the scene shortly after the shooting.
Trial Court Proceedings
During the trial, evidence was presented, including testimonies from witnesses who identified Valdez as the shooter. The trial court rendered a decision convicting the appellant of both crimes, imposing the death penalty for murder and reclusion perpetua for illegal possession of firearms.
Appellant's Contentions
Valdez appealed his conviction, arguing:
- Insufficient evidence of guilt beyond a reasonable doubt.
- Misapprehension in recognizing treachery and aggravating circumstances such as evident premeditation and abuse of superior strength.
- Misapplication of the law regarding illegal possession of firearms, citing Republic Act 8294's amendment to the earlier decree.
Court’s Findings on Murder
The court found substantial evidence linking the appellant to the murder, including positive identifications by witnesses, despite the appellant's defenses of alibi and denial. The proximity of the appellant's claimed location during the shooting did not preclude him from being at the crime scene, undermining his alibi.
Dying Declaration
Testimonies highlighted that the victim identified the appellant as his assailant shortly after being shot, classifying these statements as dying declarations permissible under the rules of court, given they were made under the consciousness of impending death.
Evaluation of Witness Credibility
Despite the appellant’s challenges regarding witness credibility—especially concerning the conditions under which identifications were made—the trial court’s determinations were upheld due to the direct and coherent evidence presented supporting the victim's identification of the accused.
Aggravating and Mitigating Circumstances
The prosecution established treachery as the sole aggravating factor since the attack was sudden and without provocation, denying the victim any chance to defend himself. The court, however, withheld other aggravating circumstances due to insufficient factual basis.
Sentencing Adju
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Case Overview
- The case involves an automatic review of the decision made by the Regional Trial Court (RTC), Branch 45, Anonas, Urdaneta, Pangasinan.
- Accused Domingo Valdez y Dulay was convicted of two crimes:
- Murder, for which he was sentenced to death.
- Illegal possession of firearms and ammunition, for which he received a sentence of reclusion perpetua.
Criminal Indictments
- Criminal Case No. U-8719:
- Date of incident: October 31, 1995.
- Location: Barangay San Roque, Municipality of San Manuel, Pangasinan.
- Charge: Murder of Labrador Valdez y Madrid, committed with intent to kill, treachery, and evident premeditation.
- Criminal Case No. U-8720:
- Charge: Illegal possession of a firearm of unknown caliber without legal authority, which was used in the murder.
Factual Background
- On the evening of October 31, 1995, Labrador Valdez was conversing with his father, Marcelo Valdez, under their nipa house.
- The victim was lying sideways on a carabao sled, positioned less than two meters from his father.
- Two gunshots were fired from the western side, injuring the victim fatally.
- Immediate responses from family members indicated that the appellant was identified as the assailant shortly after the shooting.
Medical Findings
- An autopsy conducted by Dr. Asuncion Tuvera on November 1, 1995, revealed:
- Gunshot wounds to the chest and extremities.
- Cause of death: Cardio-respiratory arrest due to severe hemorrhage from gunshot wounds.
Trial and Conviction
- The appellant entered a plea of not guilty for both charges.
- The RTC rendered a verdict convicting him of murder and illegal possession of firearms, imposing the death penalty for the murder charge and reclusion perpetua for the firearms charge.
Appellant's Arguments
- The appel