GR 241952; (March, 2021) (Digest)
G.R. No. 241952, March 17, 2021
People of the Philippines, Plaintiff-Appellee, vs. Joebert Taroma Zapata, Accused-Appellant.
FACTS
Accused-appellant Joebert Taroma Zapata was charged with two counts of Murder for the deaths of Randy M. Nuevo and Almar A. Ranien. The prosecution’s witness, Teody Tambua, testified that on August 14, 2008, the victims were at his house for a drinking session. Accused-appellant joined them, but left after getting angry when Ranien joked about his identification card. Accused-appellant returned minutes later with a bolo hidden behind his back, suddenly hacked Ranien several times, and then proceeded to hack Nuevo. Tambua ran to seek help and later found the victims dead. The autopsy confirmed hacked and stab wounds as the causes of death. The defense, presented by accused-appellant, claimed self-defense. He testified that he was invited by Tambua, whom he was not on good terms with, and upon entering, one of the victims punched him. He retaliated, saw the other victim holding a bolo, grabbed it, and hacked both men when they allegedly attacked him, claiming his vision darkened during the incident.
ISSUE
Whether the guilt of accused-appellant for two counts of Murder has been proven beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the findings of the lower courts, holding that accused-appellant’s guilt was proven beyond reasonable doubt. The Court ruled that accused-appellant failed to prove the elements of self-defense, specifically unlawful aggression on the part of the victims. The testimony of prosecution witness Tambua was found credible, straightforward, and more worthy of belief than the self-serving and inconsistent claims of the accused-appellant. The Court upheld the presence of treachery, as the attack was sudden and unexpected, depriving the victims of any chance to defend themselves. The penalty of reclusion perpetua for each count of Murder was affirmed. The Court modified the awarded damages in line with prevailing jurisprudence, increasing moral and exemplary damages to P75,000.00 each and temperate damages to P50,000.00 for each victim, in addition to P75,000.00 civil indemnity, all with 6% interest per annum from finality until fully paid.