G.R. No. L-12268; November 28, 1959
THE PEOPLE OF THE PHILIPPINES, plaintiffs-appellees, vs. JUAN MARTINEZ GODINEZ, defendant-appellant.

FACTS

Juan Martinez y Godinez, the chancellor of the Spanish Consulate in Manila, was charged with the murder of Spanish Consul Horencio Millaruelo. On the morning of May 4, 1956, a gunshot was heard from appellant’s room at the Consulate. Appellant emerged, informed staff that the Consul was shot, and asked for a doctor. The victim died shortly after. Police found appellant’s .45 caliber pistol on his table, fully cocked and loaded, along with an empty cartridge shell and a slug near the body. Ballistics tests showed the pistol was mechanically sound and would not discharge even if dropped while cocked. Appellant claimed the shooting was accidental, stating that while retrieving papers from his desk drawer with the pistol on top, he lifted the gun, and it fired, hitting the seated Consul. The prosecution established that appellant, who managed consulate funds, resented not being designated acting consul when the position became vacant, a role given to the victim instead. Appellant had expressed his disgust in a letter, calling the victim’s appointment an injustice. After trial, the Court of First Instance of Manila found him guilty of murder and sentenced him to reclusion perpetua.

ISSUE

Whether the shooting of Consul Horencio Millaruelo by Juan Martinez Godinez was accidental or constituted murder.

RULING

The Supreme Court affirmed the conviction for murder. The Court found appellant’s claim of accidental shooting unconvincing and disproved by the evidence. The pistol had multiple safety devices, required significant trigger pressure to fire, and was tested to not discharge even if dropped while cocked. Appellant’s account was inconsistent with his prior statements and the physical evidence. His actions after the shooting—such as re-cocking the pistol instead of aiding the victim—were deemed unnatural for an accidental event. The Court found that appellant had a motive to kill the victim due to his resentment over being passed over for the acting consul position. The killing was committed with treachery, as the victim was shot suddenly and unexpectedly while seated in a closed room, ensuring no risk to the appellant. The aggravating circumstance of disregard of respect due to rank was present, as the victim was the acting consul and appellant his subordinate. While evident premeditation was not proven, the presence of one aggravating circumstance without any mitigating circumstance would normally warrant the death penalty. However, for lack of the necessary votes to impose death, the penalty of reclusion perpetua imposed by the trial court was affirmed.