G.R. No. 129964-65, August 29, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARLOS MENEQUE y MONTON, accused-appellant.

FACTS

Accused-appellant Carlos Meneque, a military man, was charged with two counts of Murder for the deaths of Mario Aguilar and Ricardo Cabarang. The prosecution presented witnesses, including PNP member John Dulaca, who testified that on March 6, 1991, in Don Salvador Benedicto, Negros Occidental, Meneque, armed with an M-14 rifle, aggressively approached a house while firing shots. Meneque challenged individuals to a fight, fired towards the ceiling, and then rapidly fired his weapon as Dulaca and a companion fled. Aguilar and Cabarang, unable to escape, were shot. Other witnesses corroborated this account, detailing Meneque’s threatening behavior, his attempt to set a building on fire, and his continued shooting spree before retreating to the municipal hall.
The defense, however, presented a version of self-defense. Meneque claimed he was invited by Aguilar’s group, which later made derogatory remarks about military men. A struggle allegedly ensued when a member tried to grab his rifle, causing it to fire accidentally. Meneque asserted he only returned fire after the group shot at him as he fled. This testimony was corroborated by Rogelio de Jose. The Regional Trial Court convicted Meneque of two counts of Murder, sentencing him to reclusion perpetua for each count. He appealed the decision.

ISSUE

Whether the trial court correctly rejected the claim of self-defense and found the accused-appellant guilty of Murder qualified by treachery.

RULING

The Supreme Court affirmed the conviction. The Court meticulously applied the legal principle that one who invokes self-defense admits to the killing and bears the burden of proving by clear and convincing evidence the justifying circumstances of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The Court found Meneque’s claim utterly unconvincing. The prosecution witnesses provided a coherent and consistent narrative of an unprovoked, deliberate attack where Meneque, armed with a high-powered rifle, sought out and assaulted defenseless victims. Their testimonies were deemed credible and were corroborated on material points.
In contrast, the defense version was riddled with inconsistencies and inherent improbabilities. The claim that a struggle over the gun occurred was belied by the fact that Meneque emerged unscathed and later surrendered his weapon without signs of a recent physical altercation. The number and severity of the victims’ wounds were also inconsistent with a sudden, reflexive act of self-preservation. Having failed to prove the essential element of unlawful aggression on the part of the victims, the plea of self-defense necessarily failed. The Court also upheld the finding of treachery (alevosia), as the mode of attack—employing a rifle to suddenly fire at unsuspecting and unarmed victims—ensured the execution of the crime without risk to the assailant. The penalty of reclusion perpetua for each count of Murder and the award of civil indemnity were affirmed.