Facts:

The case involves Alberto Almojuela y Villanueva (petitioner) and the People of the Philippines (respondent). The events leading to the case occurred on November 21, 1993, in the City of Manila. Almojuela was charged with homicide after the death of Ricardo Quejong y Bello (the victim), who was fatally stabbed during a brawl. The Regional Trial Court (RTC) of Manila, Branch 39, initially received two informations: one for attempted homicide and another for homicide. The RTC dismissed the attempted homicide charge due to insufficient evidence but proceeded with the homicide case. During the trial, the prosecution presented witnesses, including Sanito Masula, who recounted that Almojuela, while drinking with friends, confronted Jose Buenhijo Paz and subsequently engaged in a fight. During this altercation, Quejong intervened, leading to a struggle between him and Almojuela. Although Masula did not witness the stabbing, he observed blood on Quejong's back. The defense claime...

Facts:

Background of the Case
The case involves Alberto Almojuela y Villanueva (Almojuela), who was charged with homicide for the death of Ricardo Quejong y Bello (Quejong). The incident occurred on November 21, 1993, in Manila. Almojuela was initially charged with both attempted homicide and homicide, but the charge for attempted homicide was dismissed due to insufficient evidence.

Prosecution’s Version
According to the prosecution, on the night of the incident, Quejong, along with Sanito Masula (Masula) and Jose Buenhijo Paz (Paz), were returning home from a party when they encountered Almojuela, who was drinking with friends. Almojuela provoked Paz, leading to a fight. During the altercation, Almojuela stabbed Paz in the arm, causing him to retreat. Quejong then intervened and grappled with Almojuela. A barangay official, Kagawad Abarquez, attempted to stop the fight by firing warning shots. Quejong was later found with stab wounds and died at the hospital.

Defense’s Version
Almojuela claimed that he was cooking when he saw Paz and his group smoking marijuana. He confronted them, but Paz cursed him. Later, Paz and Quejong challenged Almojuela to a fistfight. During the fight, Kagawad Abarquez intervened and fired warning shots. Almojuela denied using a knife and claimed he only engaged in a fistfight. He surrendered to the police the next day after learning of Quejong’s death.

RTC’s Decision
The Regional Trial Court (RTC) found Almojuela guilty of homicide, sentencing him to 6 years and 1 day to 14 years and 8 months of imprisonment. The court relied on circumstantial evidence, including the fact that Almojuela was the only one armed with a knife during the fight.

CA’s Decision
The Court of Appeals (CA) affirmed the conviction but modified the penalty to 6 years and 8 months to 12 years and 1 day, appreciating the mitigating circumstance of voluntary surrender.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Circumstantial Evidence as Basis for Conviction

   • Conviction can be based on circumstantial evidence if the following requisites are met:
     a. There is more than one circumstance.
     b. The facts from which inferences are derived are proven.
     c. The combination of circumstances produces a conviction beyond reasonable doubt.
   • In this case, the circumstantial evidence, including Almojuela’s provocation, his possession of a knife, and Quejong’s fatal injuries, collectively pointed to his guilt.

2. Inapplicability of Incomplete Self-Defense

   • Incomplete self-defense requires that the victim initiated unlawful aggression, which was not the case here. Almojuela was the aggressor, as he provoked Paz and was armed with a knife.

3. Voluntary Surrender as a Mitigating Circumstance

   • The Court affirmed the CA’s appreciation of voluntary surrender, as Almojuela surrendered to the authorities the day after the incident, fulfilling the requisites of spontaneity and intent to submit to the law.

4. Modification of Damages

   • The Court deleted the award for funeral and litigation expenses due to lack of evidence but awarded P25,000.00 as temperate damages. Interest at 6% per annum was also imposed on all monetary awards from the date of finality of the decision until fully paid.

5. Finality of Factual Findings

   • The Court upheld the factual findings of the RTC and CA, emphasizing that their conclusions were supported by the evidence and that no substantial facts were overlooked or misinterpreted.