G.R. Nos. 127759-60; September 24, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PO3 NOEL FELICIANO, accused-appellant.

FACTS

On September 29, 1994, at the Isabela Police Station in Basilan, an altercation occurred between appellant PO3 Noel Feliciano and SPO4 Santiago Miguel. SPO4 Miguel shouted invectives at Feliciano and pointed a rifle at him, but SPO3 Hupida disarmed Miguel. The station commander, P/Inspector Edgardo Miguel, intervened, disarmed Feliciano, and ordered two officers to escort Feliciano home. Approximately ten minutes later, Feliciano returned to the station. Shortly after, a gunshot was heard from outside. P/Insp. Miguel was seen clutching his chest. Feliciano then entered the station, armed himself with an M16 rifle, and fired multiple shots towards the radio room.
The prosecution presented multiple eyewitnesses, including SPO3 Hupida, SPO1 Lubaton, and PO3 Arguelles, who consistently testified to witnessing Feliciano shoot P/Insp. Edgardo Miguel outside the station and then fire an M16 rifle into the radio room, killing PO3 Roberto Arabejo and SPO4 Santiago Miguel. Feliciano claimed self-defense and denial, alleging that a struggle ensued after he was attacked by the victims upon his return to the station. The trial court convicted Feliciano of three counts of murder, imposing the death penalty for two counts.

ISSUE

Whether the trial court correctly convicted appellant PO3 Noel Feliciano of three counts of murder, appreciating the qualifying circumstance of treachery.

RULING

Yes, the Supreme Court affirmed the conviction for murder but modified the penalties. The Court found the testimonies of the prosecution witnesses credible, consistent, and corroborative on material points, establishing Feliciano’s guilt beyond reasonable doubt. The claim of self-defense was rejected as it was not proven by clear and convincing evidence; Feliciano failed to establish unlawful aggression on the part of the victims at the precise moment he fired the fatal shots. Treachery was correctly appreciated. The attack on P/Insp. Miguel was sudden and from behind, giving him no opportunity to defend himself. The shooting of Arabejo and SPO4 Miguel inside the station was also treacherous, as Feliciano used a high-powered rifle to fire at them while they were in the enclosed radio room, unable to flee or retaliate. However, the death penalty was reduced to reclusion perpetua for each murder count in accordance with Republic Act No. 9346 , which prohibits the death penalty. Civil indemnity, moral damages, and exemplary damages were awarded to the heirs of each victim.