Can an act of shooting someone twice while the victim is pinned to the ground by another be considered as murder qualified by treachery, despite the accused's defense that the shooting was accidental?
Case Title:
People of the Philippines vs. Elinjer Corpuz Y Daguio
G.R. No. 220486 | June 26, 2019
Facts of the Case:
Elinjer Corpuz was charged with murder for the killing of his uncle, Jerry Corpuz, on September 2, 2011, in Sta. Ignacia, Tarlac. The case arose from an altercation between Jerry and another relative, Porfirio Corpuz, where Jerry was pinned to the ground. While Jerry was restrained, Elinjer approached and shot him twice, causing his death.
The prosecution's witnesses, Ofelia Domingo Corpuz (Jerry's wife) and their son Jerick, testified that they saw Jerry being flagged down by Porfirio, after which a heated argument ensued. Ofelia and Jerick witnessed Jerry and Porfirio pushing each other, with Porfirio eventually pinning Jerry down. It was at this point that Elinjer, armed with a gun, shot Jerry twice. Jerry succumbed to his injuries on the way to the hospital.
Elinjer's defense claimed that the shooting was accidental. He stated that he was merely walking when Jerry blocked his path, leading to a confrontation where Jerry allegedly drew his own gun. A struggle ensued over the firearm, during which Elinjer claimed the gun accidentally fired twice, resulting in Jerry's death.
The trial court found Elinjer guilty of murder, ruling that the killing was attended by treachery. The Regional Trial Court sentenced him to reclusion perpetua (life imprisonment) and ordered him to pay damages to Jerry’s heirs. On appeal, Elinjer argued that the court erred in finding treachery and maintained that the shooting was accidental. The Court of Appeals affirmed the trial court’s decision, with some modifications in the monetary awards.
Primary Issue in the Supreme Court:
Did the Court of Appeals err in affirming the conviction of Elinjer Corpuz for murder, despite his claim that the shooting was accidental and without treachery?
Decision of the Supreme Court:
The Supreme Court affirmed the conviction of Elinjer Corpuz for murder. The Court ruled that treachery was present, as Jerry was pinned to the ground when Elinjer suddenly and unexpectedly shot him twice. The sudden nature of the attack deprived Jerry of any opportunity to defend himself, which qualifies the killing as murder under Article 248 of the Revised Penal Code. The Court found Elinjer’s defense of accidental shooting unconvincing and contrary to the credible eyewitness testimonies.
Dispositive Portion:
WHEREFORE, the appeal is DISMISSED for lack of merit. The Decision dated February 18, 2015, of the Court of Appeals in CA-G.R. CR-H.C. No. 06274 is AFFIRMED with MODIFICATION.
Appellant Elinjer Corpuz y Daguio is found guilty of murder and sentenced to reclusion perpetua.
Appellant is ordered to pay Php 75,000.00 civil indemnity, Php 75,000.00 moral damages, Php 75,000.00 exemplary damages, and Php 50,000.00 as temperate damages. These amounts shall earn six percent (6%) interest per annum from the finality of this decision until fully paid.
SO ORDERED.
Thought-Provoking Question:
How should courts weigh an accused’s claim of accidental shooting against the direct and consistent testimonies of witnesses that the killing was deliberate?
Important Doctrines:
-
Treachery in Murder: Treachery exists when the attack is sudden and unexpected, rendering the victim defenseless and unable to retaliate. In this case, Jerry was pinned to the ground when he was shot, leaving no chance for self-defense.
-
Credibility of Eyewitness Testimonies: Testimonies given in a straightforward and spontaneous manner, especially by those close to the victim, are generally regarded as credible unless there is evidence of improper motive.
-
Rejection of Accidental Defense: The Court emphasized that claiming accidental discharge of a firearm must be substantiated by credible evidence. Mere assertions are insufficient when contradicted by strong eyewitness accounts.
Case Classification: Criminal Law (Murder)
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🎓 In this short
educational CONTENT, we dive into a compelling criminal law case that
underscores the application of treachery as a qualifying circumstance in
murder. This content will focus on discussing important legal doctrines
from the Supreme Court’s ruling in People of the Philippines vs. Elinjer
Corpuz y Daguio, with the aim of helping law students, bar
reviewees, and future baristas to recall and understand these
doctrines efficiently.
🔍 NATURE OF THE CASE:
This is a Criminal Law case involving the crime of Murder under
Article 248 of the Revised Penal Code.
📚 CASE TITLE:
People of the Philippines vs. Elinjer Corpuz y Daguio
G.R. No. 220486 | Date of Promulgation: June 26, 2019
👥 PARTIES:
- Plaintiff-Appellee:
People of the Philippines
- Accused-Appellant:
Elinjer Corpuz y Daguio
📌 BRIEF SUMMARY:
Elinjer Corpuz was convicted of murder for shooting his uncle, Jerry Corpuz,
twice while the latter was pinned down after a scuffle with Elinjer’s brother.
Despite Elinjer’s claim that the incident was accidental, the Supreme Court
ruled that treachery was present, making it a qualified case of murder
under Article 248. The penalty of reclusion perpetua was affirmed.
💭 THOUGHT-PROVOKING
QUESTION:
Should an accused's claim of accidental shooting outweigh eyewitness accounts
pointing to deliberate execution, especially in familial conflicts?
🎯 TOP 10 IMPORTANT
DOCTRINES:
- Treachery
Defined (Art. 14, par. 16, RPC)
Treachery exists when an offender employs means ensuring the execution of the crime without risk to himself from any defense the victim might make. (p. 12) - Sudden
Attack as Treachery
Shooting a pinned victim twice, without warning, constitutes treachery as the victim is rendered defenseless. (p. 12) - Eyewitness
Testimony from Relatives
Testimony from the victim’s wife and son was found credible despite their relationship, especially absent any improper motive. (p. 11) - Self-Serving
Testimonies Are Weak
An accused’s lone claim of accidental shooting, uncorroborated by any neutral witness, is insufficient to overturn strong prosecution evidence. (p. 13) - Accidental
Killing Defense Must Be Clear
For an accidental killing defense to prosper, clear and convincing evidence must support it — mere allegations are not enough. (p. 13) - Elements
of Murder
Murder requires: (1) a person was killed; (2) accused killed the person; (3) qualifying circumstances like treachery; and (4) it is not parricide or infanticide. (p. 9) - No
Evident Premeditation Without Proof
There must be proof of planning and sufficient time for reflection for evident premeditation to be appreciated. This was absent in this case. (p. 14) - Credibility
Through Spontaneity
Testimonies delivered spontaneously and in a straightforward manner are presumed truthful and credible. (p. 11) - Monetary
Damages Must Follow Jurisprudence
Civil, moral, exemplary, and temperate damages must follow prevailing jurisprudence — all increased by the Court in this case. (p. 15) - Finality
Interest Rule
All damages awarded shall earn 6% interest per annum from the finality of the judgment until fully paid. (p. 15)
📢 DISCLAIMER:
This content is for educational purposes only. While it is based on
official court rulings, we do not guarantee infallibility. Always verify
from the Supreme Court’s official records.
🎥
Made using premium AI technology to support law learners and bar exam
takers.
🎓 Welcome, future attorneys!
This quizzer is designed to reinforce your understanding of a key criminal
law case decided by the Supreme Court involving the doctrine of treachery
in murder.
📌 Nature of the Case:
This is a Criminal Law case dealing with murder qualified by
treachery.
📚 Case Title:
People of the Philippines vs. Elinjer Corpuz y Daguio
G.R. No. 220486 | Promulgated on June 26, 2019
👥 Parties Involved:
- Plaintiff-Appellee:
People of the Philippines
- Accused-Appellant:
Elinjer Corpuz y Daguio
📝 Brief Summary:
The case involves the killing of Jerry Corpuz, who was shot twice by his
nephew, Elinjer, while already pinned to the ground by another relative.
Elinjer claimed the shooting was accidental. The Supreme Court, however, gave
weight to the direct testimonies of the victim’s wife and son and ruled that treachery
attended the killing, thereby affirming Elinjer’s conviction for murder
and imposing the penalty of reclusion perpetua.
✅ REMEMBER: The answer key will
be provided at the end of this video, so make sure to answer first
before checking!
🧠 10 HOTS (Higher Order Thinking
Skills) Multiple Choice Questions
(Easy Difficulty – Based on the Case
Above)
- What
was the main defense raised by the accused in response to the murder
charge?
A. Mistaken identity
B. Alibi
C. Self-defense
D. Accidental shooting - Which
of the following BEST describes the reason why the Court appreciated
treachery in this case?
A. The victim was alone when attacked
B. The victim was shot from behind
C. The victim was pinned down and unable to defend himself
D. The accused used a deadly weapon - What
factor contributed MOST to the Supreme Court's rejection of the accused’s
claim that the shooting was accidental?
A. The lack of a ballistic report
B. The accused’s relationship to the victim
C. The credible eyewitness accounts
D. The weapon used was illegal - Why
was evident premeditation NOT appreciated by the Court?
A. The accused was intoxicated
B. There was no proof of planning before the shooting
C. The accused had no motive
D. The killing happened in broad daylight - How
did the Court view the testimonies of the wife and son of the victim, who
were eyewitnesses?
A. Unreliable due to their relationship with the victim
B. Insufficient because they were emotionally affected
C. Biased and self-serving
D. Credible and straightforward - What
penalty was imposed by the Supreme Court upon conviction?
A. Death
B. Prision mayor
C. Reclusion perpetua
D. Arresto mayor - Which
of the following was NOT awarded by the Supreme Court?
A. Civil indemnity
B. Exemplary damages
C. Temperate damages
D. Nominal damages - What
key circumstance qualified the killing as murder?
A. Intent to kill
B. Use of firearm
C. Treachery
D. Cruelty - What
action did the accused take after the shooting, as observed by a witness?
A. Helped bring the victim to the hospital
B. Fled into the fields holding a gun
C. Surrendered to the police
D. Hid the firearm - Why
did the appellate courts give more weight to the prosecution's evidence?
A. The defense presented no witnesses
B. The evidence was supported by video
C. The testimonies were consistent and lacked improper motive
D. The defense admitted guilt
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