Facts:
1. On December 14, 1984, Renato Tac-an, aged 18, shot and killed his 15-year-old classmate, Francis Ernest Escaño III, inside a classroom at the Divine Word College in Tagbilaran City, Bohol, Philippines.
2. Tac-an and Escaño were former friends and members of the Bronx gang but grew apart due to escalating misunderstandings.
3. An altercation occurred between Tac-an and Escaño earlier that day when Escaño allegedly sat on Tac-an’s scrapbook, leading to a heated argument.
4. Tac-an temporarily left school premises and returned 15 minutes later with a loaded firearm, a Smith & Wesson Airweight .38 caliber revolver.
5. Tac-an entered the classroom and shot at Escaño multiple times; after Escaño was hit and lay defenseless on the floor, Tac-an fired at him once more, ensuring his death.
6. Tac-an then detained teachers and students in a faculty room until he was persuaded by his father to surrender the firearm.
7. Tac-an was charged with qualified illegal possession of firearms and ammunition (Criminal Case No. 4007) and murder (Criminal Case No. 4012). Both charges were consolidated and tried jointly.
8. The Regional Trial Court of Tagbilaran convicted Tac-an of both charges and sentenced him to death in each case on July 31, 1986.
9. Tac-an appealed the conviction, which was subject to automatic review by the Supreme Court.
Issues:
1. Whether the trial court erred in not accepting Tac-an’s claim of self-defense or incomplete self-defense.
2. Whether P.D. No. 1866 applied to Tac-an post-Martial Law.
3. Whether double jeopardy applied due to multiple charges stemming from the same incident.
4. Whether treachery and evident premeditation existed in the crime committed.
5. Whether the influence of dangerous drugs was a factor in the killing.
6. Whether voluntary surrender should be considered a mitigating circumstance.
7. Whether the crime involved contempt of or insult to public authorities.
Court’s Decision:
1. **Self-Defense Claim**: The plea was denied; the Court found no unlawful aggression by Escaño, the essential element for justifying self-defense under Article 11(1) of the Revised Penal Code.
2. **Applicability of P.D. No. 1866**: The court rejected the argument that P.D. No. 1866 was only applicable during martial law since no sunset provision existed within the decree and it aimed to consolidate firearm laws broadly.
3. **Double Jeopardy**: There was no double jeopardy; separate statutes addressed different offenses – illegal possession of an unlicensed firearm and murder.
4. **Treachery and Evident Premeditation**: Treachery was affirmed based on the method and suddenness of the attack, although evident premeditation was not sufficiently established due to lack of evidence underpinning plan formation and opportunity for reflection.
5. **Influence of Dangerous Drugs**: This was not substantiated by competent evidence; alleged ingestion had no medical corroboration, and circumstantial indications were insufficient.
6. **Voluntary Surrender**: Not recognized as Tac-an did not surrender to authorities but was arrested after surrendering the weapon to his brother in constrained circumstances.
7. **Contempt of Authority**: The Court ruled that teachers are considered public authorities under specific Articles 148 and 151 but not within the context meant to aggravate murder sentencing.
Doctrine:
– **Unlawful Possession and Double Jeopardy**: P.D. No. 1866 punishes firearm possession independently, and using a firearm in homicide/murder aggravates the sentence under this statute but not under the Revised Penal Code.
– **Requirements for Evident Premeditation**: Includes plan formation, indication of persistence in such plan, and enough reflective time lapse.
– **Teachers as Public Authority**: Teachers are only considered persons in authority for direct assault or resistance under Articles 148 and 151, not for aggravating offenses like murder.
Class Notes:
– **Self-Defense Requirements**: Unlawful aggression, proportional response, lack of provocation.
– **Double Jeopardy Principle**: Applies to identical charges; different statutes and facts justify multiple charges.
– **Treachery in Murder**: Sudden, unexpected, methodical attack without self-defense possibility warrants treachery.
– **Evident Premeditation**: Requires clear proof of intent development, planning indication, and time for reflection.
Historical Background:
The case occurred after the lifting of Martial Law in the Philippines, within a period focused on consolidating firearm control laws. The legal decision demonstrates efforts to balance newly codified laws against the backdrop of restored political and civil freedoms, emphasizing the courts’ role in clearly defining the interaction of concurrent legal standards in a transitioning legal context.
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