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PEOPLE v. CARLOS MANANSALA

FACTS:

Carlos Manansala is charged with murder for shooting and killing Edgardo Manansala. The incident occurred on January 21, 1997, in Caloocan City, Philippines. According to witnesses, Carlos attacked Edgardo and shot him with a .45 caliber pistol, causing his death at the Martinez Memorial Hospital. Elizabeth, Edgardo's wife, saw Carlos outside their room and woke up Edgardo when Carlos said he was going to kill him. Carlos fired two shots, causing Edgardo to fall. Elizabeth pleaded with Carlos to stop, and when he left, she brought her injured husband to the hospital, where he was declared dead on arrival. Bullet casings, a bullet, and a slug were found in their room as evidence. An autopsy showed that Edgardo suffered from injuries and a gunshot wound that entered his back and exited through his right chest.

The victim had bullet wounds on his right cheek and right chest, and his fall caused a contusion on his left cheek and a laceration on his right shoulder. A paraffin cast taken from Carlos' hands tested negative for nitrates. Police officers found the crime scene flooded with water and blood, and efforts to locate Carlos were unsuccessful. The victim's relatives did not give sworn statements and sought help from higher authorities. A murder complaint was filed against Carlos, and evidence, including empty shells and a slug, were sent for examination. The firearm used by Carlos was licensed under a firearms amnesty program, but the ballistic test envelope was destroyed. Carlos had a criminal record. After his arrest, Carlos claimed that the shooting was accidental and in self-defense, alleging that Edgardo was involved in drug selling along with his wife and another relative. Concerned citizens had also filed a petition regarding drug activities in the community.

The article mentioned alleged drug pushers and a shabu supplier, along with a police officer and a cousin of Elizabeth involved in protecting them. During cross-examination, Carlos stated that he did not see any blood on Edgardo and was not aware that he had been shot when Carlos fired the gun. He claimed to have left the room in confusion upon learning the news of Edgardo's shooting.

ISSUES:

  1. Whether the trial court erred in convicting the appellant of murder based on the testimony of the prosecution's lone eyewitness.

  2. Whether the defense of self-defense can be established by the appellant.

  3. Whether the gun fired when Calo pulled the trigger.

  4. What did Calo do with his gun after it did not fire.

  5. What was the position of the victim when he uttered the statement "Calo, huwag kang magbiro ng ganyan."

  6. What was the position of the victim when Calo fired his gun.

  7. Whether it is possible for the gunman to shoot the victim while he was lying down.

  8. Whether or not the aggravating circumstance of dwelling can be appreciated despite not being alleged in the information.

RULING:

  1. The trial court did not err in convicting the appellant of murder based on the testimony of the prosecution's lone eyewitness. The appellate court gives great reliance on the findings of the trial judge in assessing conflicting testimonies, particularly when there is only one eyewitness to the commission of the crime. In this case, the testimony of the eyewitness was described as categorical, clear, and convincing, and was found to be in consonance with the findings of the medico-legal officer who conducted the autopsy on the victim's body.

  2. The defense of self-defense cannot be established by the appellant. The appellant claimed that he acted in self-defense when he grabbed the gun from the victim, resulting in the accidental firing of the gun. However, the trial court rejected this claim and found that the evidence adduced by the prosecution was more credible. The appellant failed to prove that he was in immediate and grave danger and that it was necessary to use force to protect himself from such danger.

  3. The gun did not fire when Calo pulled the trigger.

  4. After the gun did not fire, Calo cocked the gun and pointed it at Edgar.

  5. The victim was lying down when he uttered the statement "Calo, huwag kang magbiro ng ganyan."

  6. The victim was still lying down when Calo fired his gun.

  7. It is possible for the gunman to shoot the victim while he was lying down.

  8. The aggravating circumstance of dwelling cannot be appreciated because it was not alleged in the information.

PRINCIPLES:

  • The assessment of conflicting testimony of witnesses is greatly relied upon the trial judge, who has the means to observe the witnesses at the stand and make judgments on their credibility.

  • The evaluation of the trial court is particularly important when there is only one eyewitness to the commission of the crime.

  • The testimony of a single, trustworthy, and credible witness can be sufficient to convict an accused, even when it is opposed by several witnesses for the defense.

  • The defense of self-defense requires the accused to prove that there was an unlawful aggression, reasonable necessity of the means employed to prevent or repel the aggression, and lack of sufficient provocation on the part of the person defending himself.

  • Burden of proof is on the accused to establish self-defense as a convincing justification for the killing.

  • Fleeing the scene of the crime and going into hiding is not the reaction of an innocent man.

  • The reputation for truth and veracity of a witness is not dependent on their alleged involvement in illegal activities.

  • The killing may be considered attended and qualified by treachery if there is evidence of the employment of means, methods, or manner of execution that ensures the safety of the offender from any defense or retaliation.

  • The execution of the criminal act must be preceded by cool thought and reflection upon a resolution to carry out the criminal intent during the space of time sufficient to arrive at a calm judgment in order to establish evident premeditation.

  • The right of the accused to be informed of the nature and cause of the accusation against him includes the requirement that qualifying and aggravating circumstances must be alleged in the information.

  • Procedural rules, particularly those that are favorable to the accused, may be given retroactive effect even to actions pending and undecided at the time of their passage.

  • In cases where no aggravating or mitigating circumstances can be appreciated, the penalty for murder is reclusion perpetua.