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PO1 CRISPIN OCAMPO Y SANTOS v. PEOPLE

FACTS:

This case involves an appeal from the Court of Appeals (CA) Decision affirming the Regional Trial Court's (RTC) decision finding accused-appellant Police Officer 1 (PO1) Crispin Ocampo guilty of homicide. Accused-appellant was charged with the crime of homicide for willfully shooting and killing Mario De Luna. The prosecution presented witnesses who testified that accused-appellant poked a gun at one of the victims and later fired several shots at Mario De Luna, resulting in his death. The defense, on the other hand, claimed self-defense and presented a witness who testified that the shooting was precipitated by the victim's unprovoked knife attack on accused-appellant. The RTC convicted accused-appellant and imposed a penalty of imprisonment and monetary damages. On appeal, the CA affirmed the conviction but modified some of the monetary damages awarded. The sole issue for resolution in this case is whether the prosecution was able to prove accused-appellant's guilt beyond reasonable doubt. The Court reviewed the case records and affirmed accused-appellant's conviction.

ISSUES:

  1. The sole issue for resolution is whether the prosecution was able to prove accused-appellant's guilt beyond reasonable doubt.

  2. Whether the plea of self-defense is acceptable.

  3. What is the appropriate penalty for the crime of homicide.

  4. Whether the awards for indemnity and damages are proper.

  5. Whether attorney's fees should be awarded.

  6. Whether interest should be imposed on the monetary awards for damages.

RULING:

  1. The Court is convinced that accused-appellant is guilty of homicide. The court found that accused-appellant failed to prove the first element of self-defense: unlawful aggression on the part of the victim. The physical evidence of the bullet trajectory negated appellant's claim of self-defense. The victim cannot be considered as the aggressor since there was an eyewitness who attested that accused-appellant shot the victim without any provocation. The means employed by accused-appellant was also grossly disproportionate to the victim's alleged unlawful aggression. Hence, the court ruled that accused-appellant's plea of self-defense is unacceptable.

  2. The plea of self-defense is not acceptable.

  3. The appropriate penalty for the crime of homicide is an indeterminate penalty of imprisonment from six (6) years and one (1) day of prision mayor as minimum to twelve (12) years and one (1) day of reclusion temporal as maximum.

  4. The awards for indemnity and damages are modified as follows: P75,000 as civil indemnity, P75,000 as moral damages, and P25,000 as temperate damages.

  5. Attorney's fees should not be awarded.

  6. Interest should be imposed on all the monetary awards for damages at the legal rate of six percent (6%) per annum from the date of finality of the decision until fully paid.

PRINCIPLES:

  • Findings of trial courts on the credibility of witnesses deserve a high degree of respect.

  • Accused who admit that they are the authors of the death of the victim and anchor their defense on self-defense have the burden of proving the justifying circumstance.

  • Requisites for self-defense: (1) unlawful aggression on the part of the victim; (2) reasonable necessity of the means employed to prevent or repel the attack; and (3) lack of sufficient provocation on the part of the person engaged in self-defense.

  • Physical evidence ranks higher in the hierarchy of trustworthy evidence and must be upheld when it contradicts the testimonies of witnesses.

  • In the absence of evidence showing any improper motive on the part of the witness to testify falsely against the accused, the testimony of the witness is worthy of full faith and credit.

  • The means employed in self-defense must not be unreasonable or excessive.

  • The plea of self-defense must be supported by clear and convincing evidence.

  • The penalty for homicide under Article 249 of the Revised Penal Code is reclusion temporal. The Indeterminate Sentence Law is applicable in imposing the penalty.

  • Civil indemnity in favor of the heirs of the victim must be automatically imposed against the accused without need for further proof.

  • Competent evidence must be presented to support the claim for compensatory damages.

  • The award for moral damages may be adjusted according to prevailing jurisprudence.

  • Attorney's fees may be awarded only if the grounds provided under Article 2208 of the Civil Code are present.

  • Interest may be imposed on monetary awards for damages at the legal rate.