**Facts:**
– **Stage Play and Frequent Meetings:** Delfin Muit’s wife, Rosario Muit, and Rodolfo Torrero were involved in a stage play and frequently met for Barangay duties, spawning rumors of an affair that reached Delfin Muit in December 1975.
– **Incident Date and Invitation:** On February 26, 1976, around 2:45 PM, Torrero and his companions were invited by Muit to rest at his house while passing by post-picnic.
– **Confrontation:** Inside the house, Muit confronted Torrero about his frequent visits to his wife and gifting food/money to his children. Despite Torrero and his wife’s explanations, tensions escalated.
– **Shooting:** Torrero tried to leave to avoid trouble, but Muit followed him and, from his doorstep, fired a .45 caliber pistol, hitting Torrero first below the nape.
– **Subsequent Shots:** Muit continued firing, striking Torrero’s left arm and chest while Gubatan attempted to restrain him. Torrero fell to the ground but the final shot missed due to Gubatan’s intervention.
– **Aftermath:** Torrero died on-site. Muit then surrendered himself and his weapon to the Tamban Police Patrol Base.
**Procedural Posture:**
– **Trial Court Decision:** Convicted Delfin Muit of murder on July 24, 1978, sentencing him to reclusion perpetua with P22,000 in total damages to the victim’s heirs.
– **Appeal by Muit:** Muit filed an appeal citing due process violations, improper denial to present a witness, and rejection of his self-defense claim.
**Issues:**
1. **Right to Present Defense Witness:** Whether the Trial Court erred in denying Muit’s request to reopen the trial to present an additional witness.
2. **Right to Due Process:** Whether due process was violated by the Trial Court through disregard of evidence, violation of the right to remain silent, and alleged judicial bias.
3. **Self-Defense Claim:** Whether the Trial Court erred in rejecting Muit’s plea of self-defense and accidental firing.
4. **Appropriate Qualification of Crime:** Whether the crime requires the elevation due to treachery or evident premeditation.
**Court’s Decision:**
1. **Presentation of Witness:** The Supreme Court upheld the Trial Court’s decision, indicating that the presentation of the additional witness, Jesus Evangelista, would not significantly affect the case outcome as his testimony related to events post-dating the crime.
2. **Due Process:** The accused was found to have been accorded due process. Defense contentions about ignored evidence or accruing bias were dismissed as unsupported, and the procedural standards of a fair trial were met.
3. **Self-Defense and Accident:** Muit failed to prove self-defense convincingly. The Court found sufficient evidence showing that Muit shot Torrero treacherously from behind without any provocation or Aggression from Torrero.
4. **Qualification of Crime:** While confirming the murder charge, the Supreme Court did not find adequate evidence to support evident premeditation. However, treachery was adequately proven. The penalty was adjusted considering the mitigating circumstances of voluntary surrender and obfuscation due to jealousy.
The penalty was modified to an indeterminate sentence ranging from eight (8) years of prision mayor to fourteen (14) years and eight (8) months of reclusion temporal, affirming the remaining aspects about damages and costs.
**Doctrine:**
– **Treachery and Self-Defense:** Proof of treachery invalidates a claim of self-defense. The manner of attack and the lack of opportunity for the victim to respond play a crucial role in establishing treachery.
– **Evident Premeditation Requirements:** Evident premeditation requires clear evidence of the time when the intent to commit the crime was formed, an act indicating persistence, and sufficient time for reflection between the intention and execution.
**Class Notes:**
1. **Treachery (Abtreach):** Sudden attack from behind leaving no chance for defense (Art. 14, RPC).
2. **Self-Defense:** Requires unlawful aggression from the victim, reasonable necessity, and lack of sufficient provocation from the accused (Art. 11, RPC).
3. **Evident Premeditation:** Determination of crime, indication of persistence, and time for reflection (People v. Causi).
4. **Voluntary Surrender:** Mitigates punishment if the accused surrenders voluntarily post-crime (Art. 13(7), RPC).
5. **Penalties for Murder:** Ranges from reclusion temporal maximum to death (Art. 248, RPC).
**Historical Background:**
The case highlights societal issues during the mid-1970s in the Philippines, including the interplay of personal relationships, rumors, and baranggay (village) politics impacting serious criminal occurrences. The procedural justice, highlighting thorough appellate review, underscores the Philippine judiciary’s commitment to due process even amidst highly personal cases.
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