### Facts
– **April 2007:** Eligio Donato was invited by Edmundo Gonzales to the house of Eduardo Gonzales. Upon arrival, Eduardo, armed with a .22 caliber firearm, along with Edmundo, fired six shots at Donato, hitting him three times.
– Donato succumbed to his injuries before receiving medical treatment.
– Eduardo Gonzales claimed self-defense, arguing that Donato arrived at his home armed and threatened to kill him, leading to a struggle where the firearm discharged unintentionally.
– The prosecution presented witness Eduardo Rodriguez and the physical findings that contradicted Eduardo’s self-defense narrative, while Eduardo’s own witness, Teofilo Posadas, corroborated parts that damaged Eduardo’s claim.
– **January 5, 2009:** The RTC ruled against Eduardo, dismissing the self-defense claim due to lack of evidence of unlawful aggression and sentenced him to reclusion perpetua for murder, qualified by treachery and evident premeditation.
### Procedural Posture
– Eduardo Gonzales appealed to the Court of Appeals (CA) arguing misappreciation of the evidence by the RTC.
– **July 28, 2010:** The CA dismissed the appeal, affirming the RTC’s decision but not ruling on evident premeditation.
– Eduardo further appealed to the Supreme Court, questioning the sufficiency of the evidence and the rejection of his self-defense claim.
### Issues
1. Whether the evidence presented sufficiently proved Eduardo Gonzales’s guilt beyond a reasonable doubt.
2. Whether self-defense was justifiably claimed by Eduardo Gonzales.
3. Whether treachery and evident premeditation were present to qualify the killing as murder.
### Court’s Decision
1. **Sufficiency of Evidence and Claim of Self-Defense**
– **Unlawful Aggression:** The Court found that no evidence supported Eduardo’s claim that Donato acted with unlawful aggression. The testimony and physical evidence showed Donato was unarmed and ambushed.
– **Reasonable Necessity:** The number of shots and the location of the gunshot wounds demonstrated an intent to kill, not merely to repel.
– **Lack of Provocation:** Eduardo’s firing upon Donato was found to be the act of initial aggression, negating Eduardo’s claim.
2. **Treachery and Evident Premeditation**
– **Treachery:** Evidence showed that Donato was attacked suddenly and without the opportunity to defend himself, fulfilling the criteria of treachery.
– **Evident Premeditation:** The Supreme Court found insufficient evidence to establish evident premeditation.
3. **Credible Eyewitness Testimony**
– The Court upheld the credibility of the prosecution’s eyewitness testimony, as found consistent by the lower courts, and dismissed the arguments of inconsistency and ill-motive toward Eduardo Gonzales.
### Doctrine
– **Self-Defense:** The burden of proof for self-defense lies on the accused, who must show unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation.
– **Treachery:** To establish treachery, the attack must be sudden and unexpected, leaving the victim with no opportunity to defend or retaliate.
– **Evident Premeditation:** Requires proof of a decided plan to commit a crime, an act manifesting that the plan was adhered to, and sufficient time for the accused to reflect on his actions.
### Class Notes
– **Key Elements of Self-Defense (Art. 11, Revised Penal Code):**
1. Unlawful aggression.
2. Reasonable necessity of the means employed.
3. Lack of sufficient provocation.
– **Key Elements of Treachery (Art. 14, Revised Penal Code):**
1. Sudden, unexpected attack ensuring the safety of the aggressor.
2. Method of execution carefully chosen to prevent any defense by the victim.
### Historical Background
– **Context:** This case underscores the critical evaluation of self-defense claims in the Philippine legal system and the degree of scrutiny applied to witness testimonies and physical evidence in criminal trials.
– **Legal Precedence:** Provides guidelines for interpreting elements of self-defense and treachery, reflecting the judicial principle that such defenses are not to be lightly assumed without convincing evidence.
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