G.R. No. 181052 - Belbis, Jr. y Competente vs. People

Rodolfo Belbis, Jr. and Alberto Brucales, the petitioners, were convicted by the Regional Trial Court (RTC) of Tabaco City, Albay for the crime of homicide in connection with the death of Jose Bahillo.
The petitioners later elevated their case through a Petition for Review on Certiorari under Rule 45, seeking reversal of the RTC decision and the Court of Appeals (CA) affirmation with modification.

Jose Bahillo, the victim, served as a Barangay Tanod in Sitio Bano, Barangay Naga, Tiwi, Albay.
On December 9, 1997, at around 9:00 p.m., Jose departed his home to attend to his barangay duties.
At approximately 10:00 p.m., Veronica Dacir, his live-in partner, heard him shouting. Upon approaching, she observed blood on his back and shorts and learned from him that he was being held by petitioner Alberto Brucales while petitioner Rodolfo Belbis, Jr. stabbed him.

Jose was initially taken to St. Claire Medical Clinic in Tiwi, Albay, and was attended by Dr. Bernardo Corral.
He was transferred to other medical facilities – first to Ziga Memorial District Hospital in Tabaco, and then to Albay Provincial Hospital – where he was confined for six days.
Dr. Sancho Reduta and other attending physicians detailed multiple stab wounds: two in the lumbar area and two in the left buttock (both medial and lateral aspects), which later contributed to complications.
Despite temporary improvement, financial constraints prevented timely follow-up treatment, and on subsequent dates (January 1, 7, and 8, 1998), Jose’s condition worsened.
Autopsy findings, conducted by Dr. Wilson Moll Lee of the NBI, indicated multiple organ failure with a special emphasis on severe kidney damage, establishing a connection between the stab wounds, secondary infection, and his eventual death on January 8, 1998.

Testimonies from various witnesses including Veronica Dacir, SPO1 Lerma Bataller, and several doctors described the events:

The victim’s statement immediately after being stabbed, identifying his assailants by name.
Testimonies regarding the sequence of struggle, including the exchange over the bolo (a bladed weapon), where petitioner Rodolfo admitted to handling and using the weapon.

Petitioners, through their own testimonies and the accounts of other medical experts (e.g., Dr. Olga Bausa and Dr. Edwin Lino Romano), argued that their actions were taken in self-defense after being attacked by Jose.
The petitioners maintained that even though petitioner Rodolfo admitted to stabbing, it was done as a means of defense against an ongoing unlawful aggression.

At trial, the prosecution introduced documentary evidence and expert testimonies linking the stab wounds to Jose’s death.
The RTC convicted the petitioners beyond reasonable doubt, acknowledging the mitigating circumstance of incomplete self-defense – though later, the CA, in affirming and modifying the penalty, ruled that there was no mitigating circumstance of incomplete self-defense.
The petitioners also raised issues regarding the admissibility of the victim’s statements (alleged dying declaration versus statements as part of the res gestae) and the validity of their claim of self-defense, including voluntary surrender.

Whether the Court of Appeals erred in characterizing the victim’s statements to Veronica Dacir and SPO1 Lerma Bataller as dying declarations under Section 37, Rule 130 of the Rules of Court.
Whether the Court of Appeals erred in ruling that the petitioners are not entitled to the justifying circumstance of self-defense and the mitigating circumstance of incomplete self-defense.
Whether the Court of Appeals erred in holding that the stab wounds were the proximate cause of the victim’s death, considering the interval between the injury and death.
Whether the Court of Appeals erred in rejecting the existence of the mitigating circumstance of voluntary surrender by the petitioners.