G.R. No. 220486, June 26, 2019
People of the Philippines, Plaintiff-Appellee vs. Elinjer Corpuz y Daguio, Accused-Appellant

FACTS

The accused-appellant, Elinjer Corpuz, was charged with Murder for the shooting death of Jerry Corpuz. The prosecution’s evidence, primarily from eyewitnesses Ofelia (the victim’s wife) and Jerick (the victim’s son), established that on September 2, 2011, the victim was first engaged in a physical altercation with Porfirio Corpuz, Jr., the appellant’s brother. During this struggle, Porfirio pinned the victim to the ground. The appellant then appeared, approached the pinned victim, and shot him twice. The defense presented a starkly different version, claiming the shooting was an accident that occurred during a struggle over a gun allegedly drawn by the victim. The Regional Trial Court convicted the appellant of Murder, qualified by treachery, and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction but modified the awarded damages.

ISSUE

Whether the Court of Appeals erred in affirming the appellant’s conviction for Murder, specifically in upholding the finding that the killing was attended by treachery.

RULING

The Supreme Court dismissed the appeal and affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the assessment of witness credibility is best undertaken by the trial court. The prosecution witnesses provided a clear, consistent, and credible narrative of the incident. The Court found the defense of accidental shooting unconvincing and inherently improbable. On the central legal issue, the Court ruled that treachery (alevosia) was correctly appreciated. The qualifying circumstance of treachery is present when the offender employs means, methods, or forms in the execution of the crime that ensure its commission without risk to themselves arising from any defense the victim might make. Here, the victim was already pinned to the ground and immobilized by the appellant’s brother when the appellant approached and shot him at close range. This sudden and unexpected attack, delivered while the victim was in a helpless position, effectively deprived him of any opportunity to defend himself or retaliate. Thus, the killing was qualified to Murder. The penalty of reclusion perpetua was affirmed. The monetary awards were modified in accordance with prevailing jurisprudence to P75,000 each as civil indemnity, moral damages, and exemplary damages, and P50,000 as temperate damages, all with 6% interest per annum from finality until fully paid.