PEOPLE v. REYES, G.R. No. 224498 | 2018 - Synopsis Only
PEOPLE OF THE PHILIPPINES, Appellee,
-versus-
PFC ENRIQUE REYES, Appellant.
G.R. No. 224498, FIRST DIVISION, January 11, 2018,
Ponente: TIJAM, J.
Doctrine:
The jurisprudential standards for a finding of unlawful aggression clearly negate accused-appellant's argument. Granting they were true, neither the "looming" threat perceived by accused-appellant nor the remarks overheard by his nephew satisfies the requirement of an actual, menacing, sudden and unexpected danger to accused-appellant's life. To constitute imminent unlawful aggression, the attack must be at the point of happening and must not be imaginary or consist in a mere threatening attitude. Furthermore, as the trial court found, the supposed threat overheard by Adelardo actually made "no specific or definite reference to (accused appellant). The Court is thus unconvinced that there was a real peril to accused-appellant's life when he killed Danilo.
There is treachery when the offender, in committing any of the crimes against persons, employs means or methods which tend to directly and specially ensure its execution, without risk to himself arising from the defense which the offended party might make. When alleged in the information and clearly proved, treachery qualifies the killing and elevates it to the crime of murder.
Synopsis:
Enrique Reyes was convicted of the murder of Danilo Estrella in the case of People of the Philippines v. Enrique Reyes. The incident took place on August 13, 1990, when Enrique fired his armalite rifle upwards, and Danilo was shot from behind, causing him to fall to the ground. Enrique then took the gun tucked in Danilo's waist and fired it upwards three times before placing it in Danilo's hand. When the police arrived, Enrique surrendered himself with the firearms he used. Danilo was declared dead due to multiple gunshot wounds, and Enrique claimed self-defense.
Enrique invoked self-defense, claiming that he overheard Danilo and his comrades planning to kill someone and fired his weapon in fear for his family's safety. However, the RTC found Enrique guilty of murder with the qualifying circumstance of treachery, as they did not find self-defense present in the killing. The CA agreed with the RTC's findings on self-defense but downgraded the conviction from murder to homicide by finding no aggravating circumstances.
The Supreme Court ruled that self-defense was not present in the killing. Unlawful aggression is an indispensable element of self-defense, and if no unlawful aggression attributed to the victim is established, self-defense is unavailing. Enrique's contention that the "looming" death threat from Danilo's group became real and evident when he overheard Danilo's plan to kill him did not satisfy the requirement of an actual, menacing, sudden, and unexpected danger to accused-appellant's life. The second element of self-defense was also absent, as Enrique's infliction of multiple gunshot wounds on the victim was neither commensurate nor reasonable.
However, the Supreme Court found treachery present in the killing. Treachery is established when the offender employs means or methods that tend to directly and specially ensure its execution without risk to himself arising from the defense that the offended party might make. In this case, Enrique's shots were multiple and successive, depriving Danilo of any chance to run or defend himself and repel the attack.
Therefore, the Supreme Court reinstated the RTC's conviction of murder with the qualifying circumstance of treachery. This case serves as a reminder that self-defense must meet specific requirements to be considered valid, and the absence of one element can lead to a conviction for a higher crime.
Nature of Petition:
This is an appeal from the June 10, 2015 Decision[1] of the Court of Appeals (CA) in CA-G.R. CR-HC No. 05671, which affirmed with modification the June 25, 2012 Decision[2] of the Regional Trial Court (RTC), Branch 54, Manila, in Criminal Case No. 91-97103, modifying accused-appellant PFC Enrique Reyes' conviction from Murder to Homicide, and the CA's February 3, 2016 Resolution[3] which denied his Motion for Reconsideration.
Dispositive Postion:
WHEREFORE, the Decision of the Court of Appeals dated June 10, 2015 in CA-G.R. CR-HC No. 05671 is MODIFIED in that accused-appellant is held guilty of murder and sentenced to a penalty of ten (10) years and one (1) day of prision mayor, as minimum, to seventeen (17) years, four (4) months and one (1) day of reclusion temporal, as maximum. Furthermore, accused-appellant shall pay civil indemnity, moral damages and exemplary damages, each in the amount of P100,000.00, as well as temperate damages in the amount of P50,000.00. The civil indemnity and all damages payable by accused-appellant are subject to interest at the rate of six percent (6%) per annum from the finality of this Decision until fully paid.