People v. Guillermo

G.R. No. 113787 (January 28, 1999)

Facts:

The case involves Ceferino Guillermo, who was accused of murdering Ronnie de la Cruz and attempting to murder Michael de la Cruz on December 15, 1991, in Barangay Uban, Aguinaldo, Ifugao Province. Ceferino and Ronnie were second-degree cousins, and tensions arose due to Ceferino's suspicion that his wife, Carmen, was having an affair with Ronnie. This suspicion led to a grudge between the two men, resulting in an altercation that prompted Ronnie's father, Eusebio de la Cruz, Sr., to send Ronnie away for a time to ensure his safety.

On the night of the incident, a fellowship was being held at the Pentecostal Church, where Ronnie and Michael de la Cruz were present. After stepping outside to relieve themselves, they were confronted by Ceferino, who shot Ronnie at close range with a Garand rifle. The gunfire also struck Michael, who was positioned two meters behind Ronnie. Witnesses, including Michael and Eusebio de la Cruz, Jr., testified that Ceferino was the shooter. Darlina Guillermo, another witness, saw Ceferino fleeing the scene with a gun and his dog.

The trial court found Ceferino guilty of murder complexed with frustrated murder, sentencing him to reclusion perpetua and ordering him to pay damages to the victims' families.

Legal Issues:

1. The credibility of the prosecution witnesses, particularly regarding their testimonies and any alleged biases.
2. Whether the crime committed should be classified as murder complexed with frustrated murder or homicide complexed with frustrated homicide.
3. The presence of treachery and evident premeditation as qualifying circumstances for the crime.

Arguments:

For the Prosecution:

• Witnesses, including Michael de la Cruz and Eusebio de la Cruz, Jr., positively identified Ceferino as the shooter.
• The attack was sudden and unexpected, qualifying it as treacherous.
• The prosecution argued that Ceferino's motive stemmed from jealousy and prior altercations with Ronnie.

For the Defense:

• Ceferino challenged the credibility of the witnesses, citing inconsistencies in their testimonies and questioning their motives due to familial ties to the victim.
• The defense argued that the attack was frontal and did not exhibit treachery, and that there was no evident premeditation as there was no clear evidence of planning prior to the shooting.
• The defense contended that the crime should be classified as homicide complexed with frustrated homicide rather than murder.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding Ceferino guilty of murder complexed with frustrated murder. The court reasoned that:

1. The testimonies of the witnesses were credible despite the defense's claims of bias. The court noted that familial relationships do not inherently discredit a witness's testimony unless improper motives are shown.
2. The attack was characterized by treachery, as Ronnie was caught off guard and unable to defend himself when shot at close range.
3. The court found that while evident premeditation was not established, the presence of treachery was sufficient to classify the crime as murder. The court emphasized that the attack's suddenness and the victim's lack of awareness constituted treachery, regardless of the attack's frontal nature.
4. The court also noted that the injuries sustained by Michael de la Cruz constituted frustrated murder, as he was wounded but survived due to timely medical intervention.

The court modified the trial court's decision regarding the actual damages awarded, stating that the claims were not sufficiently supported by receipts.

Significant Legal Principles Established:

• The credibility of witnesses is not automatically undermined by familial relationships unless there is evidence of improper motive.
• Treachery can be established even in frontal attacks if the victim is caught unaware and unable to defend themselves.
• The classification of crimes can hinge on the presence of qualifying circumstances, such as treachery and premeditation, which must be proven by the prosecution.