G.R. No. 268355 - People vs. Domingo Banguilan y Gulan

Accused-appellant Domingo Banguilan y Gulan was charged with murder under Article 248 of the Revised Penal Code for the death of John Paloma y Fuentes.
The incident occurred on or about December 29, 2017, at Caloocan City, Metro Manila.
Domingo was accused of stabbing John with a balisong with treachery and evident premeditation, causing fatal wounds.

Sheila Caitan, a coworker of the victim, was with John and his family at the employer’s canteen.
John stepped outside to check on his roosters; Sheila followed due to noise.
Sheila heard John shout and saw Domingo stabbing John on the left neck while John was sitting.
Analyn Paloma, John’s wife, found John covered in blood and took him to the hospital where he was pronounced dead.
Security guard E-Are Perez testified seeing Domingo stab John, ordering Domingo to stop, and ultimately arresting him after a brief pursuit and confrontation.
Police Chief Inspector Caryl Escaro conducted the autopsy, confirming two fatal stab wounds on John (neck and upper back).

The Regional Trial Court found Domingo guilty of murder.
Found treachery present due to the sudden, deliberate attack.
The testimonies of Sheila and E-Are were credible and consistent.
Domingo’s claim of self-defense was dismissed due to being under intoxication and lack of corroboration.
Evident premeditation claim was not ruled on.

Affirmed the conviction for murder.
Held Domingo failed to prove self-defense due to lack of clear and convincing evidence.
Found no evidence John was armed with a metal rod.
The location of fatal wounds (neck and upper back) negated self-defense claim.
Agreed with the presence of treachery—the attack was sudden and from behind.

Domingo appealed the CA decision.
Supreme Court analyzed the credibility of witnesses; deferred to trial court’s credibility assessment.
Affirmed failure of Domingo to prove elements of self-defense: unlawful aggression, reasonable necessity, and lack of provocation.
Noted Domingo was intoxicated, further weakening his testimony.
Reviewed the treachery finding and found it unproven beyond reasonable doubt due to lack of evidence on how the attack commenced.
Held treachery requires proof of the method and deliberate adoption of means to ensure execution without risk.
Without treachery or premeditation, the crime is reduced to homicide.
Modified sentence to prision mayor minimum to reclusion temporal maximum.
Adjusted damages awarded accordingly.

Justice Lazaro-Javier concurred in conviction but argued treachery was proven.
Reasoned that Domingo deliberately chose a manner of attack that ensured victim’s defenselessness.
Highlighted external facts and sequence showing deliberate and conscious attack from behind with fatal wounds.

Whether the Court of Appeals erred in affirming the conviction of Domingo for murder.
Whether the elements of self-defense were established by the accused.
Whether the qualifying circumstance of treachery attended the killing.
Whether evident premeditation was proven.
The proper classification and penalty for the homicide/murder committed.