Case Summary (G.R. No. 188269)
Charge and Initial Trial
Ugaddan was charged with homicide, accused of intentionally shooting Baquiran, leading to the latter's death due to a gunshot wound to the neck. Throughout the trial, Ugaddan pleaded not guilty. The Regional Trial Court (RTC) of Isabela ultimately convicted him, finding him guilty beyond reasonable doubt under Article 249 of the Revised Penal Code. As no mitigating circumstances were found to favor the accused, Ugaddan was sentenced to a prison term ranging from eight years and one day of prison correctional to fourteen years, eight months, and one day of reclusion temporal, along with civil damages to the victim's heirs.
Appellate Review
Dissatisfied with the RTC decision, Ugaddan appealed to the Court of Appeals, which affirmed the trial court's ruling with a minor modification regarding the minimum penalty, correctly stating it should be under "prision mayor" and not under "prision correctional." This affirmation further solidified the findings of fact from the lower court, reiterating that the evidence supported the conclusion of Ugaddan's guilt.
Petitioner’s Defense and Testimony
Ugaddan’s defense rested on the assertion of his innocence, claiming the victim had attempted to grab his service firearm during a struggle, and that a second shot, originating from outside the canteen, fatally struck Baquiran. He contended that one shot was fired accidentally while his gun was pointed upwards. Additionally, he challenged the credibility of prosecution witnesses, alleging fabrication of the victim's dying declaration.
Circumstances of the Incident
The events leading up to Baquiran's shooting were corroborated by multiple eyewitness accounts. On the evening of the incident, Ugaddan allegedly confronted Baquiran, who was seated, after an entertainer reported that Baquiran had pointed a gun at her. Emerging from his seat, Ugaddan approached Baquiran and fired his weapon, resulting in Baquiran being transported to a hospital where he succumbed to his injuries.
Assessment of Credibility
The trial court's factual determinations, reviewed by the appellate court, were upheld due to the weight of credible testimonies from witness accounts, the evidentiary procedures followed during the investigation, and the medical findings that corroborated the injury patterns consistent with the alleged shooting scenario. The Court made note that the credibility of eyewitnesses and the circumstances surrounding the shooting favored the prosecution's narrative and rejected Ugaddan's alternative accounts as implausible.
Dying Declaration and Its Admissibility
The case also hinged on the admissibility of Baquiran's dying declaration, which took place a short time before his death and wherein he identified Ugaddan as the shooter. The court upheld this declaration as a valid hearsay exception due to the declarant's consciousness of imminent death and his competency to testify regarding the events leading to his demise. Thus, the d
...continue readingCase Syllabus (G.R. No. 188269)
Background of the Case
- Petitioner Jesus Ugaddan was charged with homicide for the death of fellow policeman Paulino Baquiran.
- The incident occurred on January 27, 1991, in Tumauini, Isabela, Philippines.
- The charge detailed that Ugaddan, with intent to kill and without just motive, assaulted Baquiran, resulting in a fatal gunshot wound to the neck.
Initial Trial and Conviction
- After pleading not guilty, Ugaddan was tried and convicted by the Regional Trial Court (RTC) of Isabela.
- The RTC decision found Ugaddan guilty beyond reasonable doubt of homicide, under Article 249 of the Revised Penal Code.
- The imposed penalty was reclusion temporal, with a range of twelve years and one day to twenty years.
- Due to the application of the Indeterminate Sentence Law, the RTC sentenced Ugaddan to a minimum of eight years and one day of Prision Correctional to a maximum of fourteen years, eight months, and one day of Reclusion Temporal.
- Additionally, Ugaddan was ordered to pay the heirs of Baquiran ₱60,000.00 for civil damages.
Appeal to the Court of Appeals
- Ugaddan appealed the RTC's decision to the Court of Appeals, which affirmed the judgment with a slight modification regarding the minimum penalty.
- The appellate court corrected that the minimum penalty should be classified as Prision Mayor instead of Prision Correctional.
- The decision was largely upheld, with costs awarded against Ugaddan.
Grounds for Appeal to the Supreme Court
- Ugaddan raised