**Facts:** On May 27, 2000, an incident happened in Tondo, Manila, resulting in the death of Mario De Luna y Hallare due to gunshot wounds inflicted by PO1 Crispin Ocampo, who was charged with homicide. Upon arraignment, Ocampo pleaded not guilty. The prosecution’s version presented witnesses who testified that the deceased was shot by Ocampo during a drinking session without provocation. In contrast, the defense claimed self-defense, asserting that De Luna attacked Ocampo with a knife, prompting Ocampo to shoot De Luna.
The Regional Trial Court (RTC) convicted Ocampo of homicide, with the Court of Appeals (CA) affirming this decision, albeit modifying monetary damages awarded. Ocampo’s appeal to the Supreme Court centered on questioning the validity of his conviction based on the prosecution’s failure to conclusively prove his guilt beyond reasonable doubt.
**Issues:**
1. Whether the prosecution was able to prove Ocampo’s guilt beyond reasonable doubt.
2. Appropriateness of the penalty imposed.
3. Determination of monetary damages.
**Court’s Decision:**
1. **Guilt Beyond Reasonable Doubt:** The Supreme Court found that both the RTC and CA correctly appreciated the facts as presented by the witnesses. Despite Ocampo’s claim of self-defense, he was unable to prove unlawful aggression on the part of the victim, a key component for claiming self-defense. Physical evidence in the form of the trajectory of the bullets contradicted Ocampo’s narrative, further negating his plea of self-defense.
2. **Penalty:** The Court affirmed the indeterminate penalty of six (6) years and one (1) day of prision mayor as minimum to twelve (12) years and one (1) day of reclusion temporal as maximum, considering the mitigating circumstance of voluntary surrender without any aggravating circumstances.
3. **Monetary Damages:** The Court modified the monetary awards, instructing Ocampo to pay the heirs of Mario de Luna P75,000 as civil indemnity, P75,000 as moral damages, and P25,000 as temperate damages, adjusting the amounts in line with prevailing jurisprudence. All awards for damages shall earn interest at a legal rate of 6% per annum from the date of the finality of the decision.
**Doctrine:** The Supreme Court reiterated the principle that in cases where self-defense is invoked, the burden of evidence shifts to the accused to prove the justifying circumstance of self-defense, specifically the elements of unlawful aggression, reasonable necessity of the means employed to prevent or repel it, and lack of sufficient provocation on the part of the person defending themselves.
**Class Notes:**
– Self-Defense in Criminal Law: Requires proof of (1) unlawful aggression, (2) reasonable necessity of means employed to prevent or repel attack, and (3) lack of sufficient provocation.
– Credibility of Witnesses: Trial court’s determination given significant deference due to their ability to directly observe the witnesses’ demeanor.
– Physical Evidence: Takes precedence over testimonial evidence when contradictions arise.
– Indeterminate Sentence Law: Applicable in assigning penalties, especially with existing mitigating circumstances without aggravating circumstances.
– Monetary Damages: Automatic civil indemnity for homicide/murder; variances in temperate and moral damages based on jurisprudence.
**Historical Background:** This case highlights the judicial processes involved in criminal cases within the Philippine legal system, especially in handling claims of self-defense. It also underscores the role of physical evidence and witness testimonies in the adjudication of criminal liability and the application of jurisprudential principles in determining penalties and damages.
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