Title
Supreme Court
People vs. Zapata y Viana
Case
G.R. No. 197046
Decision Date
Jul 21, 2014
George Zapata shot wife Queeny at close range, claimed it was accidental; court ruled intentional, convicted of parricide, upheld reclusion perpetua.

Case Summary (G.R. No. 217169)

Factual Antecedents

On the day of the incident, George Zapata was engaged in a drinking session at his home with relatives. The timeline indicates that by approximately 7 PM, a gunshot was heard from the bedroom, where George shot Queeny at close range. After the incident, instead of seeking help, he left the scene with their three-year-old daughter, Angel. The police were notified, and evidence gathered included an empty cartridge and testimony from medical personnel that established the nature and trajectory of the gunshot wound.

Trial Court Ruling

The trial court, leveraging the evidence, concluded that the appellant's claim of an accidental shooting lacked credibility. The court found that George deliberately fired the gun and subsequently convicted him of parricide. He was sentenced to suffer the penalty of reclusion perpetua and ordered to indemnify the victim's heirs with actual damages, death indemnity, and moral damages.

Appellate Court Ruling

On appeal, the appellant maintained that the shooting was accidental. However, the Court of Appeals affirmed the trial court’s decision, agreeing that the evidence convincingly demonstrated intentionality in the act of shooting. The appellate decision modified the lower court ruling only to increase the amount of exemplary damages awarded to the victim's heirs.

Evidence and Credibility Analysis

The courts concluded that George’s assertion of an accidental discharge was implausible. His background as a former military corporal implied familiarity with gun safety, which made his handling of the firearm—by carelessly placing it atop a cabinet without proper precautions—particularly alarming. The courts noted that the sequence of events indicated clear intent and that George’s immediate flight from the scene further undermined his argument of an accidental shooting.

Conclusion and Legal Principles

The ruling affirmed that all necessary elements o

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