GR 213214; (April, 2015) (Digest)
G.R. No. 213214 , April 20, 2015
People of the Philippines, Plaintiff-Appellee, vs. Eugene Samuya, Accused-Appellant.
FACTS
Accused-appellant Eugene Samuya and Rudy Samuya were charged with Murder for the killing of Gabriel Samonte on November 19, 2006. The prosecution alleged that while the victim and others were sitting outside a house, Rudy arrived asking for someone and cocked a gun at one of them. Eugene then arrived and, without warning, shot Gabriel in the chest. The victim ran away, and Eugene chased him; another gunshot was heard. Gabriel was later found dead. The post-mortem examination confirmed a fatal gunshot wound. Eugene admitted shooting Gabriel but claimed self-defense, alleging the victim rushed at him with a knife. Rudy denied seeing this alleged attack. The Regional Trial Court convicted Eugene of Murder, appreciating treachery, and sentenced him to reclusion perpetua, while acquitting Rudy due to lack of proof of conspiracy. The Court of Appeals affirmed the conviction but modified the damages awarded.
ISSUE
Whether the Court of Appeals correctly upheld Eugene Samuya’s conviction for Murder.
RULING
Yes, the conviction is affirmed with modification. The prosecution proved all elements of Murder: (a) Gabriel Samonte was killed; (b) Eugene killed him; (c) the killing was attended by treachery; and (d) it was not parricide or infanticide. Treachery was present as the attack was sudden and unexpected, depriving the victim of any chance to defend himself, even if frontal. Eugene’s claim of self-defense, whether as a justifying or mitigating circumstance, fails for lack of credible corroboration; his co-accused even denied seeing the alleged unlawful aggression. The penalty of reclusion perpetua is affirmed, with ineligibility for parole. The awards of damages are modified: civil indemnity of ₱75,000.00, moral damages increased to ₱75,000.00, exemplary damages of ₱30,000.00, and temperate damages of ₱25,000.00 in lieu of actual damages, all with legal interest at 6% per annum from finality until fully paid.