G.R. No. 108381 ; March 7, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AMADEO I. ACAYA, accused-appellant.

FACTS

On June 20, 1988, at a baptismal party in Basco, Batanes, accused-appellant Amadeo Acaya, a soldier, arrived drunk and armed with an M-16 rifle. He fired a shot in the air, approached the victim, Efren Rodriguez, and shot him in the face. As Rodriguez fell, Acaya shot him again in the back. Prosecution eyewitness Felipe Viola testified to these events. The autopsy confirmed two fatal gunshot wounds. The prosecution charged Acaya with Murder, qualified by treachery.
The defense presented a different version. Acaya claimed he was too intoxicated to recall the events. Defense witness Jesus Batifora testified that the shooting was accidental, occurring during a struggle over the firearm. The Regional Trial Court convicted Acaya of Murder, sentencing him to reclusion perpetua and ordering him to pay indemnity and moral damages.

ISSUE

The core issues were: (1) whether the prosecution proved Acaya’s guilt beyond reasonable doubt, particularly the qualifying circumstance of treachery; (2) whether his intoxication exempted him from criminal liability; and (3) the propriety of the awarded damages.

RULING

The Supreme Court modified the conviction from Murder to Homicide. The Court upheld the credibility of prosecution witness Viola, finding his detailed account consistent and corroborated by physical evidence, notwithstanding his consumption of alcohol. However, the Court ruled that treachery was not sufficiently established. The prosecution failed to prove that Acaya consciously adopted a mode of attack specifically intended to ensure the execution without risk to himself. The suddenness of the attack alone, without evidence of deliberate planning, does not constitute treachery.
On the defense of intoxication, the Court held it did not constitute a complete exemption but was merely a mitigating circumstance. For intoxication to be an exempting circumstance, it must be proven that the accused was so utterly deprived of reason and self-control as to be incapable of discerning the wrongfulness of his act. Acaya’s ability to walk, operate his firearm, and interact with others after the incident negated this complete deprivation. The aggravating circumstance of taking advantage of public position was also present. With one mitigating and one aggravating circumstance offsetting each other, the penalty for Homicide was imposed in its medium period. Applying the Indeterminate Sentence Law, the Court imposed a prison term. The award of P50,000.00 as civil indemnity was affirmed, but the award of P100,000.00 as moral damages was deleted for lack of factual basis in the record.