G.R. No. L-1567 - People vs. Salico

Rodolfo Guevarra and his son Joey Guevarra were charged under two Informations with frustrated homicide and homicide, respectively, involving the victims Erwin Ordoñez and David Ordoñez.
The alleged crimes were committed on November 8, 2000, in Alicia, Isabela, Philippines.
Frustrated homicide charge involved Rodolfo and Joey stabbing Erwin Ordoñez multiple times, causing wounds which would ordinarily lead to death, but Erwin survived due to timely medical assistance.
Homicide charge involved the stabbing and hacking of David Ordoñez by the accused, which resulted in his death.

The petitioners pleaded not guilty and claimed self-defense at the pre-trial, prompting a reverse trial procedure.
Defense Version:

Rodolfo testified that Erwin, David, and their companion Philip Vingua forcibly entered his compound, stoned his house and tricycle, and threatened him physically. He claimed he acted to defend himself after David injured him with a panabas. Rodolfo took a bolo and stabbed both Erwin and David until they fell.
Joey testified that the Ordoñez brothers and Philip were breaking into their gate and staging an attack, with David threatening to kill Rodolfo.
Neighbor Balbino Agustin corroborated the defense’s claim that stones were thrown first by the Ordoñez group, who also damaged Rodolfo’s gate and tricycle. Balbino testified about the physical struggle and Rodolfo’s stabbing of the victims in self-defense.

Erwin Ordoñez, the sole prosecution witness and survivor, testified that he and his companions were passing by when the petitioners suddenly attacked, stabbing David and then him.
Erwin denied that they threw stones or damaged the Guevarra property and that it was the petitioners who initiated aggression.
He sustained thirteen (13) stab wounds; David suffered about ten (10) stab wounds and died due to these injuries.
After the stabbing, there was stoning from people outside urging the petitioners not to kill the victims. Both brothers were brought unconscious to the hospital.

The RTC gave more weight to the prosecution’s version, finding inconsistencies in the defense testimonies and ruled the Guevarras guilty beyond reasonable doubt of frustrated homicide and homicide.
The RTC denied the claim of self-defense due to absence of unlawful aggression by the victims and imposed corresponding penalties and damages.
The Court of Appeals (CA) affirmed the RTC ruling but modified the amounts for civil indemnity and moral damages.
The CA ruled that apprehensions of self-defense were unsubstantiated since acts like verbal threats were not unlawful aggression, especially as the petitioners were inside their home, and that the severe and multiple stab wounds indicate clear intent to kill beyond self-defense.

Petitioners challenged the CA ruling on the grounds that:

The CA erred in rejecting the claim of self-defense despite purported clear and convincing evidence.
The CA improperly credited the lone prosecution witness’s testimony.
There was no participation of Joey Guevarra in the incident, warranting his acquittal.

Whether the Court of Appeals erred in failing to recognize the presence of justifying circumstance of self-defense despite evidence presented.
Whether the CA erred in giving full credence to the lone prosecution witness, Erwin Ordoñez.
Whether the CA erred in not acquitting Joey Guevarra for lack of participation in the incident.