- Petitioner
- People
- Respondent
- Joel Tañeza y Dacal
- Citation
- G.R. No. 121668
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Gonzaga-Reyes, J.
- Decided
- June 20, 2000
Summary
Joel Tañeza was convicted of murder for shooting Emerson Umandam multiple times at Lucky Ace Bakery in 1993. The Supreme Court affirmed the Regional Trial Court's conviction, rejecting Tañeza's self-defense claim and finding treachery as the qualifying circumstance since the victim was shot while sleeping. The Court upheld the credibility of prosecution witnesses, particularly eyewitness Aida Esgrina, and admitted the victim's ante mortem statement as a dying declaration. While affirming the reclusion perpetua sentence and most damage awards, the Supreme Court deleted the exemplary damages for lack of aggravating circumstances. The case demonstrates the application of treachery in murder cases and the requirements for admitting dying declarations as evidence.