## Title
People of the Philippines vs. Leonito Macagaling y Atillano, G.R. Nos. 104573-75
## Facts
On July 19, 1991, two separate informations were filed against Leonito Macagaling y Atillano for the crimes of murder and homicide, docketed as Criminal Cases Nos. 1814 and 1815. On October 29, 1991, a third information for illegal possession of a firearm and ammunition was filed under Criminal Case No. 1834. Macagaling, assisted by counsel de parte, pleaded not guilty to all charges.
The cases were consolidated and tried together. During the barangay fiesta of Calabasahan, an altercation occurred resulting in Macagaling shooting his nephew Dennis Macagaling and another individual, Teotimo Fameronag. Witnesses testified that Macagaling fired a gun at Dennis, missed, and hit Fameronag instead. Witnesses also indicated that Macagaling subsequently shot Dennis multiple times at point-blank range, ultimately killing him.
Macagaling was arrested at the scene by Pfc. Roque Fesalbon, who retrieved the firearm containing five empty shells and one live bullet. The serial number of the gun had been erased.
During the trial, the defense presented a different sequence of events, claiming that Macagaling acted in self-defense, asserting that Dennis, who was intoxicated, had threatened and shot at him first. Macagaling alleged that the injuries to Dennis were accidental, resulting from a struggle for the weapon.
## Issues
1. **Homicide (Criminal Case No. 1814 and No. 1815)**: Whether the accused acted in self-defense, or whether he was guilty of homicide.
2. **Illegal Possession of Firearm and Ammunition (Criminal Case No. 1834)**: Whether the prosecution proved beyond reasonable doubt that the accused possessed the firearm without legal authorization.
## Court’s Decision
### Homicide (Criminal Cases Nos. 1814 and 1815)
– **Issue of Self-defense**: The Court rejected Macagaling’s claim of self-defense. The Court pointed out critical inconsistencies in the defense’s narrative, especially the improbability of accidental multiple gunshot wounds. The Court also undermined the credibility of defense witness William Ferrancullo.
– **Conviction**: Without sufficient evidence of self-defense or accidental shooting, Macagaling was found guilty. The trial court’s conviction of Macagaling for homicide was affirmed.
### Illegal Possession of Firearm and Ammunition (Criminal Case No. 1834)
– **Burden of Proof**: The Court scrutinized the prosecution’s evidence on whether Macagaling’s possession of the firearm was without legal authority. The testimony provided by Pfc. Fesalbon was deemed insufficient to prove that Macagaling did not have a license. There was a noticeable lack of concrete evidence, such as a certification from the Firearms and Explosives Office.
– **Acquittal**: Due to insufficient evidence regarding the illegal possession of the firearm, Macagaling was acquitted of this charge.
## Doctrine
1. **Burden of Proof in Self-defense**: When the accused admits the killing but claims self-defense, the burden shifts to the accused to prove it by clear and convincing evidence.
2. **Illegal Possession of Firearms**: For convictions under Presidential Decree No. 1866, the prosecution must establish beyond reasonable doubt that the accused did not possess a legal license for the firearm. Simply holding a firearm does not meet the threshold of guilt without proving the absence of legal authority.
## Class Notes
1. **Elements of Self-defense**:
– Unlawful aggression
– Reasonable necessity of the means to prevent or repel it
– Lack of sufficient provocation by the defender
2. **Evidentiary Standards**:
– The prosecution must provide substantial and direct evidence for all elements of the alleged crime, including any negative elements, such as the lack of a firearm license.
3. **Presidential Decree No. 1866**:
– Defines the crime of illegal possession of firearms.
– Requires substantiating evidence, such as certifications from the Philippine National Police or relevant authorities, to prove the absence of a legal license.
## Historical Background
The case highlights legal principles pertinent to criminal jurisprudence in the Philippines, especially dealing with self-defense and illegal possession of firearms. The ruling demonstrates the rigorous standards that the Supreme Court applies to proof and the necessity for detailed and specific evidence in criminal litigation. This serves as a precedent for similarly contested defenses and charges, underscoring both procedural and substantive legal mandates in Philippine criminal law.
Leave a Reply