**Facts:**
1. **Incident Event (July 6, 1991):** Around 11:45 PM, Edwin Alberto and Demetrio Mendoza, residents of Valenzuela, Metro Manila, were disposing garbage at a dumpsite near Mariposa Bed Factory when Irving Flores, a security guard at the factory, allegedly drunk, emerged with a gun and fired at them without provocation.
2. **Chase and Shooting:** Alberto and Mendoza ran after the initial gunfire, but Flores pursued them, firing again from about fifteen meters away. A bullet hit Alberto in the back, who exclaimed, “Demet, I was hit,” before being taken to the hospital by Mendoza. Alberto was pronounced dead on arrival from a gunshot that lacerated his lungs.
3. **Initial Investigation:** At around 1:35 AM, Patrolmen Patag and Tapar arrived at the crime scene, acting on a report. Residents informed them that the shooter was inside the Mariposa Factory. Upon inquiries, a security guard named Eman identified Flores, who was discovered to be the shooter and was found drunk. Flores surrendered a .38 caliber revolver, which was legally registered to his security agency.
4. **Trial:**
– Flores, asserting innocence, claimed he fired warning shots to deter three suspicious men, including the victim, who allegedly tried to enter the factory premises. His claim was unsupported by other testimony.
5. **Court Verdict:** The trial at the RTC Valenzuela, Branch 172, concluded with Flores’s acquittal on illegal firearm possession, as the firearm was licensed and authorized for his security duties. However, he was convicted of murder for Alberto’s death and sentenced to reclusion perpetua with indemnity obligations.
**Issues:**
1. **Credibility of Prosecution Eyewitness:** Whether the trial court erred in heavily relying on Mendoza’s testimony to convict Flores.
2. **Qualification of Crime:** Whether the crime should be considered murder or a lesser offense, such as homicide, factoring in any mitigating circumstances like lack of treachery or voluntary surrender.
3. **Mitigating Circumstances:** Assessment of Flores’s defense claim that his actions were in incomplete defense of property, and consideration of voluntary surrender.
**Court’s Decision:**
1. **Eyewitness Credibility:** The Supreme Court upheld the finding that Mendoza’s testimony was consistent and credible, noting the alignment of his account during cross-examination with the affidavit provided shortly after the incident.
2. **Treachery and Crime Reclassification:** The Court found no treachery proving basis—as the victim was forewarned after the initial shot—and thus reclassified the crime from murder to homicide. The evident intoxication did not provide a legal privilege of defense like treachery.
3. **Rejection of Mitigating Circumstances:** The defense of incomplete justification was rejected due to the absence of unlawful aggression by the victim. Voluntary surrender was also dismissed, as Flores merely submitted to arrest without resistance when the police approached him.
**Doctrine:**
– **Motive and Eyewitness Identification:** Proof of motive is not essential when the assailant’s identity is positively established by credible witnesses.
– **Treachery**: Requires not only taking advantage of the element of surprise but also intentional employment of a method to ensure execution of the crime without risk from defense or retaliation.
– **Voluntary Surrender:** Must be genuine and voluntary without exigencies prompting the surrender.
**Class Notes:**
– **Elements of Homicide (Article 249, Revised Penal Code):** Must involve killing with intent, without justifying circumstances like self-defense.
– **Indeterminate Sentence Law (Philippines):** Utilized in sentencing wherein penalties cover a range allowing parole consideration over fixed terms.
**Historical Background:**
The case took place during the early 1990s, a period characterized by close scrutiny of gun-related crimes and security agency regulations in the Philippines. The ruling illustrates the judicial effort to balance firearm usage for security purposes with strict legal liabilities for unwarranted use of force leading to homicides. It also reflects the judicial affirmation on issues of self-defense evaluations and the need for objective witness testimonies.
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