G.R. No. 193134 - Nadyahan vs. People

Rafael Nadyahan, the petitioner, was charged with homicide for the death of Mark Anthony D. Pagaddut in Banaue, Ifugao.
The Information alleged that on the evening of May 26, 2004, Nadyahan, armed with a knife and with intent to kill, attacked and fatally stabbed Pagaddut.
At arraignment, Nadyahan pleaded not guilty and later, during pre-trial, claimed he acted in self-defense.

According to the defense, Nadyahan was riding his motorcycle with companion Mark Apilis when they were flagged down by Marcial Acangan, accompanied by Elias Nabejet, Moreno Binwag, and Pagaddut.
Acangan requested a ride home and later also asked for a drink, which Nadyahan refused, stating that he had already spent his money on drinks earlier.
A dispute ensued when Acangan became angry, leading to physical contact where Acangan slapped Nadyahan and kicked him.
Nadyahan dismounted his motorcycle and prepared to engage in a fight. Observing Acangan’s associates picking up pieces of wood, he ran towards his companion Apilis, who was instructed to start the motorcycle.
Before the motorcycle could move, Nabejet struck Nadyahan on the back with a piece of wood. In response, Nadyahan took his knife from the motorcycle’s windshield and ran in the direction of his house.
During the ensuing chase, Nadyahan encountered Moreno Binwag and, amid a confused altercation involving Pagaddut—who had attacked him with a belt buckle—Nadyahan stabbed Pagaddut before both collapsed.
After the incident, Nadyahan briefly interacted with Apilis and proceeded toward a congressman’s house before seeking treatment for his wounds and eventually surrendering to authorities.

The prosecution presented Acangan and Nabejet as primary witnesses who testified that Nadyahan was the aggressor who suddenly attacked the victim with a knife.
Acangan stated that after a prior drinking session at Viewer’s Live Band, when Nadyahan and Apilis approached them, Nadyahan unexpectedly wielded a knife and initiated a chase and subsequent assault on Pagaddut.
Nabejet’s account similarly portrayed Nadyahan as the one who chased and stabbed Pagaddut; however, his testimony was noted for inconsistencies regarding the timing and sequence of events.
Physical evidence, including a Certificate of Death and the testimony of Dr. Antonio Ligot, confirmed that Pagaddut sustained multiple stab wounds—specifically, penetrating wounds on the right infraclavicular area, the anterior axillary fold, the base of the neck, and the lateral aspect of the upper arm.

The trial court evaluated the conflicting testimonies and physical evidence, ultimately finding that Nadyahan did not initiate the aggression.
Nevertheless, the court determined that his act of self-defense was “incomplete” because the response was disproportionate to the threat, as evidenced by the fatal stab wounds inflicted on vital areas of the victim’s body.
In its determination, the trial court treated incomplete self-defense as a privileged mitigating circumstance and voluntary surrender as an ordinary mitigating circumstance, sentencing Nadyahan to four (4) years and two (2) months of prision correccional medium, as minimum, and eight (8) years of prision mayor minimum, as maximum.
The Court of Appeals, in its decision rendered on December 17, 2009, affirmed the trial court’s ruling and sentence.

The petitioner raised issues on appeal, challenging the finding of incomplete self-defense and the penalty imposed without fully considering circumstances favorable to him.
The Office of the Solicitor-General supported the lower courts’ ruling on incomplete self-defense but proposed a modification of the penalty.
The Supreme Court, after a thorough review of testimonies, physical evidence, and applicable law, affirmed the rulings of the trial court and the Court of Appeals, while modifying the penalty in line with the mitigating circumstances and the provisions of Article 69 of the Revised Penal Code and the Indeterminate Sentence Law.

Whether the trial court erred in determining that Nadyahan’s act amounted to an incomplete self-defense.

The petitioner contended that he acted in legitimate self-defense and that the use of a knife was a necessary response under the circumstances.
The issue also involved whether sufficient evidence existed to shift the onus to Nadyahan in proving the justifying circumstance by clear and convincing evidence.

The adequacy of the prosecution’s evidence in establishing that the petitioner was the aggressor.

Inconsistent testimonies among prosecution witnesses raised doubt as to whether Nadyahan had instigated the altercation.

Whether the physical evidence, including the nature and locations of the stab wounds, supports the conclusion that the means employed in defense were disproportionate to the threat faced.

This issue focused on the rational equivalence between the offensive and defensive acts, particularly in light of the victim’s and his companions’ use of comparatively less lethal weapons.

The appropriateness of the penalty imposed concerning the mitigating factors, i.e., incomplete self-defense and voluntary surrender, in reducing the severity of the crime under the applicable provisions of the Revised Penal Code.