GR 194129; (June, 2015) (Digest)
G.R. No. 194129, June 15, 2015
PO1 CRISPIN OCAMPO y SANTOS, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
On May 27, 2000, in Manila, PO1 Crispin Ocampo was charged with homicide for shooting and killing Mario De Luna. The prosecution’s version, based on eyewitness accounts, stated that during a drinking session, Ocampo, without provocation, called De Luna and fired several shots at him, causing fatal wounds. The defense claimed self-defense, alleging that De Luna lunged at Ocampo with a knife, forcing Ocampo to shoot in response. Ocampo admitted to shooting the victim but asserted it was justified. The Regional Trial Court (RTC) convicted Ocampo of homicide, sentencing him to an indeterminate penalty and ordering him to pay damages. The Court of Appeals (CA) affirmed the conviction but modified the awarded damages, deleting the award for loss of earning capacity for lack of proof, reducing attorney’s fees, and awarding temperate damages instead of actual damages. Ocampo appealed to the Supreme Court.
ISSUE
Whether the prosecution was able to prove accused-appellant’s guilt beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court upheld the factual findings and credibility assessments of the lower courts, emphasizing that trial court findings on witness credibility are accorded high respect. Ocampo’s plea of self-defense failed because he did not prove by clear and convincing evidence the element of unlawful aggression on the part of the victim. The physical evidence, specifically the trajectory of the bullets which traveled downward, contradicted his claim that he fired while leaning backward to evade a knife attack; instead, it indicated the shooter was positioned higher than the victim. The Court stressed the primacy of physical evidence over testimonial evidence when they conflict. Furthermore, the prosecution eyewitness was found credible, with no evidence of improper motive. The means employed (use of a firearm) was also found disproportionate to the alleged threat. The penalty imposed by the lower courts was affirmed, and the modified awards of damages by the CA, including civil indemnity, temperate damages, and reduced attorney’s fees, were sustained.