G.R. No. L-63155 March 21, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CASTULO CORECOR, accused-appellant.

FACTS

The accused-appellant, Castulo Corecor, was convicted of murder for the shooting death of Juanito Potoy. The prosecution evidence established that on the evening of April 12, 1978, in Jaro, Leyte, the victim was drinking tuba in his kitchen when a shot was fired from under his house. The victim’s wife, Sinforosa Potoy, immediately saw her husband wounded. Using a flashlight, she looked out the window and saw Corecor running away with a long gun. The motive was established through testimony that Corecor was courting the victim’s daughter, Elisa, a courtship to which the victim strongly objected due to their being cousins. Corecor had previously molested Elisa in 1976, an incident for which his parents sought forgiveness.
The defense presented a different account, claiming self-defense. Corecor testified that he visited the Potoy house that evening and, during a conversation, the victim became angry, retrieved a homemade shotgun, and threatened to shoot him. Corecor claimed he wrested the gun away and, when the victim obtained another firearm, he shot the victim in perceived self-defense to repel the attack. The trial court rejected this version, finding the prosecution’s narrative credible and convicting Corecor of murder qualified by treachery.

ISSUE

The core issue is whether the accused-appellant successfully proved the justifying circumstance of self-defense to absolve him of criminal liability for the killing of Juanito Potoy.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court ruled that the plea of self-defense must fail. When an accused admits the killing, the burden of proof shifts to him to establish the elements of self-defense by clear and convincing evidence. These elements are: (1) unlawful aggression by the victim; (2) reasonable necessity of the means employed to repel it; and (3) lack of sufficient provocation on the part of the person defending himself. Corecor relied solely on his own testimony, which the trial court found unworthy of credence. The Court accorded great respect to the trial court’s factual findings and credibility assessments, as it had the direct opportunity to observe the witnesses’ demeanor.
The Court found the testimony of the eyewitness, Sinforosa Potoy, to be credible and consistent. It rejected the defense’s attempt to impugn the credibility of prosecution witnesses based on a minor alleged inconsistency regarding who surrendered the firearm. The Court held this detail—whether the gun was surrendered by the accused’s mother alone or together with the barangay captain—was collateral and did not affect the witnesses’ credibility on the central facts of the crime. The established facts showed a deliberate attack, not a sudden confrontation justifying self-defense. However, the Court recognized the mitigating circumstance of voluntary surrender. Consequently, the penalty was modified to an indeterminate sentence of ten years and one day of prision mayor as minimum, to eighteen years, eight months and one day of reclusion temporal as maximum, and the indemnity was increased to thirty thousand pesos.