Case Summary (G.R. No. 206768)
Applicable Law
This case is governed by the Revised Penal Code of the Philippines and pertinent provisions of the 1987 Philippine Constitution, given that the decision date is within the stipulated period.
Case Background
The initial ruling on February 23, 2001, dismissed a separate petition (G.R. No. 103613) while affirming the decision in G.R. No. 105830. Tangan was sentenced to an indeterminate penalty of imprisonment ranging from six years and one day of prision mayor to fourteen years, eight months, and one day of reclusion temporal, alongside monetary obligations for indemnity, funeral expenses, attorney’s fees, and moral damages to the victim’s heirs.
Motion for Reconsideration
Tangan filed a Motion for Reconsideration, arguing that the Supreme Court erred by disregarding mitigating circumstances acknowledged by the trial court and the Court of Appeals, which led to an increased penalty that severely impacted him. He emphasized the psychological burden of potentially being reincarcerated after serving more than four years of preventive confinement.
Review of Facts and Evidence
Despite Tangan's assertions of self-defense, it was noted that he did not raise this defense during the trial. The Court found that the mitigating circumstances of incomplete self-defense, sufficient provocation, and passion and obfuscation were indeed acknowledged by the lower courts. However, the Supreme Court's review revealed that the evidence did not substantiate these findings, thus it was within its prerogative to correct the lower courts’ assessments.
Assessment of Physical Evidence
Physical evidence contradicted Tangan's account of the incident, establishing details of the shooting's mechanics. Testimony from a medical examiner indicated that the gun was fired from a distance of approximately two to three inches, suggesting a direct confrontation between Tangan and the victim rather than an accidental shooting. The nature of the revolver's mechanism further supported this conclusion, as it requires deliberate action to discharge.
Eyewitness Testimony
Eyewitness testimonies corroborated the physical evidence, asserting that Tangan drew the firearm from his vehicle and shot the victim without justification. One defense witness's testimony was scrutinized due to inconsistencies, undermining Tangan's credibility.
Legal Determination of Self-Defense
The Court ruled that there was no unlawful aggression on the part of the victim, as the altercation was characterized by verbal disputes rather than physical confrontation. The Court established that unlawful aggression is a necessary precondition for asserting self-defense, which was absent in this case. Consequently, the Court concluded that Tangan's actions represented a disproportio
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Case Overview
- This case involves Eladio C. Tangan as the petitioner and The Court of Appeals along with the People of the Philippines as respondents.
- The Supreme Court rendered its decision on January 15, 2002, with the case number G.R. No. 105830, following a previous decision on February 23, 2001.
Background of the Case
- The Supreme Court affirmed the decision of the Court of Appeals with modifications regarding the penalties imposed on Tangan.
- Tangan was sentenced to an indeterminate penalty ranging from six years and one day of prision mayor to fourteen years, eight months, and one day of reclusion temporal.
- He was also ordered to pay various damages to the victim's heirs.
Motion for Reconsideration
- Tangan filed a Motion for Reconsideration arguing that the Supreme Court erred in disregarding mitigating circumstances recognized by the lower courts.
- He expressed concern over the increased penalty, which he described as exposing him to the "ahorrifying reality" of possible reincarceration after being preventively confined for over four years.
Self-Defense Claim
- Notably, Tangan did not raise self-defense during the trial.
- Despite this, the trial court and the Court of Appeals acknowledged the presence of mitigating circumstances, such as incomplete self-defense, sufficient provocation, and passion and obfuscation.
Supreme Court's Review
- Upon reviewing the case, the Supreme Court found that the evidence did not support the lower courts' findings.
- The Court emphasized