Ugaddan v. Court of Appeals
REITERATIONFacts
The Antecedents: On January 27, 1991, at approximately 9:00 PM, Police Corporal Jesus Ugaddan was in Geraldine Canteen. Police Pat. Paulino Baquiran was also present, seated about five meters away. An entertainer complained to Ugaddan that Baquiran had pointed a gun at her. Ugaddan approached Baquiran from behind, drew his service firearm, and shot Baquiran once in the upper right side of the neck. Baquiran fell, and was brought to the hospital. On January 28, 1991, while hospitalized and under dextrose, Baquiran, in the presence of Pat. Juan Anapi and Dr. Brainard Vagay, answered questions posed by Anapi. Baquiran affixed his thumbmark on the written declaration with his own blood. Baquiran died on January 29, 1991, with the cause of death certified as cardio-respiratory arrest secondary to gunshot wound. Procedural History: The Regional Trial Court (RTC) of Isabela convicted petitioner Jesus Ugaddan of homicide, sentencing him to an indeterminate penalty and ordering him to pay civil damages. The Court of Appeals (CA) affirmed the RTC decision with a modification regarding the minimum penalty, denominating it as prision mayor instead of prision correccional. The CA's decision was promulgated on November 27, 1995. The Petition: Petitioner Ugaddan appealed to the Supreme Court, imputing error to the CA for affirming the RTC's findings of fact and for giving credence to the prosecution's witnesses. He maintained his innocence, claiming the victim grabbed his service pistol, and they were grappling for its possession when two shots were heard. He admitted one shot came from his gun, fired upwards due to the struggle, but alleged the fatal shot came from outside the canteen window. He also assailed the credibility of the prosecution witness who testified on the victim's dying declaration, claiming it was fabricated.
Issue(s)
Whether the Court of Appeals erred in affirming the trial court's findings of fact and giving credence to the prosecution's witnesses, and the credibility of the petitioner's defense. Whether the petitioner's defense of grappling for the firearm and the victim being shot from outside the canteen is credible. Whether the dying declaration of the victim is admissible in evidence.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals in toto, upholding the conviction of the petitioner for homicide.
Ratio Decidendi
On the issue of factual findings, credibility of witnesses, and the petitioner's defense: The Court reiterated the hornbook precept that factual findings of the trial court, especially when affirmed by the Court of Appeals, are deemed final and conclusive by the Supreme Court when supported by substantial evidence. Such findings should not be disturbed absent any significant facts and circumstances that were overlooked, ignored, or disregarded by the trial court which, if considered, would affect the outcome of the case. The petitioner's defense of grappling and being shot from outside was found to be unbelievable and contrary to the physical evidence and the testimony of eyewitnesses. The Court found the petitioner's version not probable under the circumstances, noting inconsistencies with the medical findings regarding the bullet's trajectory and the implausibility of the victim grappling for the gun while already incapacitated. The Court rejected the petitioner's claim of a grappling incident and the victim being shot from outside the canteen. The Court found it incomprehensible why Baquiran would grab Ugaddan's gun if he was also armed. Furthermore, the trajectory of the bullet, as shown by the medico-legal certificate, was consistent with the testimony that Ugaddan shot Baquiran while the latter was seated, and inconsistent with the claim of a shot fired from outside. The two-shot theory was deemed a product of imagination, contradicted by eyewitnesses who heard only one shot from the petitioner's gun. The trial court's rejection of this theory was affirmed, noting that the petitioner did not mention two shots in his counter-affidavit, suggesting it was an afterthought. Even assuming the dying declaration was inadmissible, the Court found that it would not affect the overwhelming weight of evidence pointing to the petitioner's guilt, considering the testimony of several eyewitnesses who positively identified the petitioner as the shooter. The Court emphasized that evidence must be credible in itself and not just proceed from a credible witness. The petitioner's version of events was found to defy common experience and observation. The Court affirmed the penalty imposed by the lower courts. Under Article 249 of the Revised Penal Code, homicide is punished by reclusion temporal. With no mitigating or aggravating circumstances, the medium period of the penalty is imposable. Applying the Indeterminate Sentence Law, the minimum penalty was correctly determined from the penalty one degree lower (prision mayor), and the maximum penalty from reclusion temporal in its medium period. The modification by the Court of Appeals regarding the minimum penalty being prision mayor was correct. On the petitioner's defense of grappling and being shot from outside: The Court rejected the petitioner's claim of a grappling incident and the victim being shot from outside the canteen. The Court found it incomprehensible why Baquiran would grab Ugaddan's gun if he was also armed. Furthermore, the trajectory of the bullet, as shown by the medico-legal certificate, was consistent with the testimony that Ugaddan shot Baquiran while the latter was seated, and inconsistent with the claim of a shot fired from outside. The two-shot theory was deemed a product of imagination, contradicted by eyewitnesses who heard only one shot from the petitioner's gun. The trial court's rejection of this theory was affirmed, noting that the petitioner did not mention two shots in his counter-affidavit, suggesting it was an afterthought. On the admissibility of the dying declaration: The Court held that dying declarations are admissible in evidence as an exception to the hearsay rule under Section 37 of Rule 130. The declaration in this case met the accepted elements for admissibility: it concerned the crime and surrounding circumstances of the declarant's death, was made under the consciousness of impending death, the declarant would have been competent to testify, and it was offered in a case where the decedent was the victim. The victim's weakened state and aversion of pain created an impression of imminent death. The absence of the declarant's signature was adequately explained by the dextrose administration. No ill motive could be attributed to the police officer who took the declaration, who was a childhood friend of the petitioner and was merely performing his duty. The presumption of regularity in the performance of official duty favored the police officer's testimony.
Main Doctrine
Factual findings of the trial court, especially when affirmed by the Court of Appeals, are deemed final and conclusive by the Supreme Court when supported by substantial evidence, and should not be disturbed absent any significant facts or circumstances that were overlooked, ignored, or disregarded by the trial court which, if considered, would affect the outcome of the case. Dying declarations are admissible as an exception to the hearsay rule if they concern the crime and surrounding circumstances of the declarant's death, were made under the consciousness of impending death, the declarant would be competent to testify, and the declaration is offered in a case where the decedent is the victim.