Facts:

• Petitioner Carlos Arcona y Moban and his brother Benito Arcona y Moban were charged with Murder and Frustrated Murder in separate criminal cases (Criminal Case Nos. 6408 and 6409).
• The incidents occurred on June 27, 1986, in Barangay Labog, Brooke's Point, Palawan.
• The charges alleged that the brothers conspired to kill Napoleon Ong and attempted to kill Edgardo Talanquines.
• During the trial, it was established that Napoleon Ong and Edgardo Talanquines were attacked while walking home from a birthday party.
• Napoleon was stabbed by Carlos, and Edgardo was hit with a bamboo stick.
• Napoleon died from his injuries, while Edgardo survived.
• Carlos claimed self-defense, stating that Napoleon had attacked him first with a bolo.
• The trial court convicted Carlos of Homicide and acquitted Benito in Criminal Case No. 6408.
• In Criminal Case No. 6409, Benito was convicted of Slight Physical Injuries, and Carlos was acquitted.
• Carlos was sentenced to an indeterminate penalty ranging from six years and one day of prision mayor as minimum to fourteen years and one day of reclusion temporal as maximum, and ordered to pay civil indemnity and damages.
• Carlos appealed to the Court of Appeals, which affirmed the trial court's decision but increased the civil indemnity to P50,000.00.
• Carlos then filed a petition for review with the Supreme Court.

Issue:

• (Unlock)

Ruling:

• The Supreme Court denied the petition for review, affirming the conviction of Carlos Arcona for Homicide and the sentence imposed by the tr...(Unlock)

Ratio:

• The Supreme Court held that Carlos Arcona failed to prove the elements of self-defense.
• The Court emphasized that when an accused admits to the killing but claims self-defense, the burden of proof shifts to the accused to show that the killing was justified.
• Carlos did not provide clear and convincing evidence that he was not the unlawful aggressor, that there was a lack of sufficient provocation on his part, and that he employed reasonable means to prevent or repel the aggression.
• The presence of Napoleon's unsheathed bolo and the shout "Caloy, I will kill you"...continue reading