People v. Languido
REITERATIONFacts
1. The Antecedents: Kahar Sundang Languido alias "Saydona" (Languido) was initially charged with frustrated murder. The Information was later amended to murder after the victim, NASRUDIN BAUDI @ URAK (Baudi), succumbed to death. The Information alleged that Languido, armed with a handgun, with intent to kill, and with treachery and evident premeditation, attacked and shot Baudi from behind, inflicting multiple gunshot wounds that caused his death. Prosecution witness Muslima S. Rasam testified that she saw Languido shoot Baudi in the head, fire three more shots into his body, and kick him before leaving. Police Staff Sergeant Kerwin Val M. Antatico testified about Languido's arrest at the scene with a gun. Languido, as the lone defense witness, claimed self-defense, alleging Baudi pointed a gun at him first, and he shot Baudi during a struggle for the weapon. He also claimed a prior altercation with Baudi due to jealousy over his wife. 2. Procedural History: The Regional Trial Court (RTC) found Languido guilty beyond reasonable doubt of murder, noting his failure to provide evidence of unlawful aggression by Baudi. The RTC sentenced him to reclusion perpetua and ordered payment of civil indemnity, moral damages, exemplary damages, and temperate damages. Languido appealed to the Court of Appeals (CA). The CA upheld the conviction for murder, finding that Languido failed to prove self-defense, and that the number and location of gunshot wounds showed intent to kill, belying self-defense. The CA modified the monetary awards for damages. Languido subsequently filed a Notice of Appeal with the CA, which forwarded the records to the Supreme Court. 3. The Appeal: In his Supplemental Brief, Languido asserted that the RTC and CA gravely erred by basing his conviction on inconsistent testimony of prosecution witnesses. He reiterated his claim of self-defense, stating he was held at gunpoint. The Office of the Solicitor General (OSG), representing the People of the Philippines, argued that the prosecution's evidence proved Languido's guilt beyond reasonable doubt, emphasizing that the eyewitness testimony and police investigation were incompatible with self-defense, and that multiple shots, including to the head, demonstrated intent to kill.
Issue(s)
Whether the Court of Appeals was correct in finding accused-appellant Kahar Sundang Languido alias "Saydona" guilty beyond reasonable doubt of murder. Whether there was sufficient evidence to prove that a justifying circumstance (self-defense) existed. Whether the inconsistencies in the prosecution witnesses' testimonies should lead to Languido's acquittal.
Ruling
The Appeal is DISMISSED. The assailed Court of Appeals August 10, 2023 Decision in CA-G.R. CR HC No. 02946-MIN is AFFIRMED. Accused-appellant Kahar Sundang Languido alias "Saydona" is found GUILTY beyond reasonable doubt of murder and is sentenced to suffer the penalty of reclusion perpetua and is ordered to pay the amounts of PHP 75,000.00 as civil indemnity, PHP 75,000.00 as moral damages, PHP 75,000.00 as exemplary damages, and PHP 50,000.00 as temperate damages. All monetary awards are subject to six percent interest per annum from finality of this Decision until fully paid.
Ratio Decidendi
On Issue 1 & 2: The Supreme Court affirmed the conviction for murder, finding that Languido failed to establish his claim of self-defense. When an accused admits to killing the victim and invokes self-defense, the burden of proof shifts to the accused to prove by clear and convincing evidence the existence of the justifying circumstance. Languido's claim that Baudi was the initial aggressor who pointed a gun at him was unsubstantiated by any physical or testimonial evidence. This claim was directly contradicted by eyewitness Rasam's account, who testified that Languido abruptly appeared and shot Baudi in the head without provocation, then fired three more shots into his body and kicked him as he fell. The Court emphasized that unlawful aggression, the primordial element of self-defense, was absent, as Baudi did not exhibit aggression towards Languido when he was shot. Furthermore, even assuming unlawful aggression, Languido's actions of shooting Baudi multiple times, including in the head and after he had fallen, were disproportionate to the alleged threat, thus failing the requisite of reasonable necessity of the means employed. Therefore, all three components of self-defense were found to be absent, rendering Languido's claim untenable. On Issue 3: The Supreme Court held that the alleged inconsistencies in the prosecution witnesses' testimonies were minor and did not warrant Languido's acquittal. The Court noted that while Rasam's account of calling for aid and bringing Baudi to the hospital differed slightly from PSSg. Antatico's version of arriving at the scene and arresting Languido, these were typical discrepancies arising from differing perspectives of eyewitnesses. Such minor inconsistencies, which do not affect the central incident of the crime or the positive identification of the accused as the assailant, do not impair the witnesses' credibility. The Court reiterated that factual findings of the trial court, especially when affirmed by the Court of Appeals, deserve great weight and respect, as the trial court is in the best position to assess the probative weight of testimonies. Ultimately, Languido's admission of killing Baudi fortified the case against him, rendering the conflicting testimonies on minor details irrelevant to the conviction for murder.
Main Doctrine
An accused's claim of self-defense relieves the prosecution of the burden of demonstrating that the accused committed the crime charged. The accused must now prove by clear and convincing evidence that the justifying circumstance exists. If the accused is unable to prove this, a contradiction in the prosecution witness' testimony that has no bearing on any of the elements of the crime will not absolve the accused. The three requisites for self-defense are unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation on the part of the person defending himself.