Facts:

This case involves the petitioner, Salvador Andalís y Morallo, who was accused of homicide against Pio Gonowon, occurring on December 25, 1992, in San Agustin, Iriga City. On that fateful Christmas Day, a drinking session was underway between Gonowon, Andalis, and several others, which escalated following a verbal altercation between Andalis and Gonowon. The prosecution's narrative suggests that Andalis fatally stabbed Gonowon during this confrontation, leading to a charge under Article 249 of the Revised Penal Code. In contrast, Andalis's defense centered on the claim that he acted to protect the honor of his wife when he allegedly found Gonowon attempting to embrace and kiss her.

The trial court found Andalis guilty of homicide, citing his failure to demonstrate that he had acted in defense of a relative, given that there was no evidence of unlawful aggression from Gonowon at the time of the stabbing. Evidence presented by the prosecution included testimonies from wit

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Facts:

Incident Overview

• The case involves Salvador Andalis y Morallo, the accused, charged with the crime of homicide for the stabbing death of Pio Gonowon on Christmas Day, December 25, 1992.
• The incident took place in San Agustin, Iriga City, during a drinking session attended by several individuals.
• The prosecution and defense provide conflicting narratives regarding the events preceding the fatality.

Prosecution’s Version of Events

• During the drinking session that commenced early in the morning (around 9:00 A.M.) and continued until the incident occurred at about 3:00 P.M., tensions escalated between Andalis and Gonowon.
• Witness Alex Embestro testified that:
• Andalis joined the group later and exchanged heated words with Gonowon.
• After a brief altercation, Andalis struck Gonowon with a chair, chased him, and stabbed him repeatedly with a fan knife (abalisonga), inflicting fatal wounds on his back.
• Another eyewitness, Justo Retrita, corroborated the sequence of events by stating:
• He observed Gonowon being chased and fatally stabbed multiple times by Andalis.
• The victim attempted to escape but ultimately fell on a cemented area where the fatal stabbings occurred.
• The post-mortem report by Dr. Loreto G. Leonido confirmed:
• The victim sustained three incised wounds on his back consistent with the use of a sharp-edged weapon.
• Additional minor injuries (such as a contusion on the forehead) were noted, possibly from a blunt impact or fall.

Defense’s Version of Events

• The defense contends that:
• Andalis acted in defense of his spouse when she called for help after Gonowon allegedly attempted to molest her.
• Testimonies by Vicente Orlain (a neighbor), Vivian Andalis (the accused’s wife), and Flora Andalis Salvadora (his sister) support the claim that the incident was triggered by an attack on the wife’s honor.
• Andalis admitted to stabbing Gonowon but argued:
• That his actions were a reaction to discovering Gonowon’s inappropriate approach toward his wife.
• That the route taken by him and the acquisition (or alleged non-acquisition) of a weapon from the scene undermines the prosecution’s narrative.
• The defense sought to introduce the contention that Gonowon was intoxicated—if not under the influence of drugs—to explain his alleged behavior, although this claim was not substantiated by independent evidence.

Trial Court Proceedings and Findings

• The Regional Trial Court (RTC) evaluated the testimonies and documentary evidence:
• The detailed and consistent testimonies of Alex Embestro and Justo Retrita were given significant weight.
• Physical evidence, particularly the post-mortem report, substantiated that multiple stabbings occurred on the victim’s back.
• The RTC rejected the defense’s justification:
• It found that the prosecution’s account of events was more logical and consistent.
• The alleged defense of a spouse was not supported by evidence of any unlawful aggression by the victim.
• Consequently, the RTC convicted Andalis for homicide, sentencing him to suffer imprisonment between eight years of Prision Mayor to a maximum of twelve years and one day of Reclusion Temporal, along with monetary penalties for damages and indemnities.

Appellate and Supreme Court Proceedings

• Andalis elevated the case to the Court of Appeals, arguing:
• Bias in the testimony of key prosecution witnesses.
• Failure of the trial court to consider the justifying circumstance of defense of spouse.
• An erroneous conviction for homicide given the circumstances described.
• The Court of Appeals affirmed the RTC’s decision:
• It held that Andalis did not prove the existence of unlawful aggression that would justify a defensive act.
• It maintained that the evidence from the prosecution was sufficient to establish the sequence of events.
• Andalis subsequently filed a Petition for Review on Certiorari with the Supreme Court:
• He reiterated claims regarding the inconsistencies in witness narratives and the failure to consider his justification for acting in defense of his wife.
• The petition also raised new issues such as the alleged drug use by the victim.
• The Supreme Court, limited to reviewing errors of law and clearly defined exceptions for factual findings, ultimately denied the petition.

Issue:

Whether the trial court erred in convicting Andalis for homicide based on the presented evidence.

• Did the evidence sufficiently establish that Andalis acted with the intent to kill, as reflected in the multiple stabbings?
• Was there any merit in the defense’s claim that Andalis acted in defense of his spouse?
• Could the inconsistencies or alleged bias in some witnesses’ testimonies have materially affected the outcome?

Whether the lower courts properly evaluated the credibility of the witnesses and the coherence of the evidence.

• Was there a manifest error in the chain of events, especially considering the victim’s state of intoxication?
• Did the lower courts err in ignoring the new issues (e.g., the claim that the victim was under the influence of drugs) raised by the petitioner?
• Was the application of the rule regarding the burden of proof on the accused for invoking a justifying circumstance properly adhered to?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)