Facts:

The case involves Gario Alba, also known as Mario Alba, who was the accused-appellant in a murder case filed against him by the People of the Philippines. The incident occurred on January 31, 1993, at approximately 5:30 PM in Sitio Pananlaya-an, Barangay Datagon, Municipality of Pamplona, Negros Oriental. The prosecution alleged that Alba, with intent to kill and with treachery and evident premeditation, attacked and stabbed Ricky Aguilar with a knife, resulting in the victim's instantaneous death. An Information was filed against Alba on February 9, 1993, charging him with murder under Article 248 of the Revised Penal Code.

During the arraignment, Alba's counsel attempted to have him plead guilty to the lesser offense of homicide, which the prosecution rejected, leading Alba to plead not guilty. The trial featured testimonies from several witnesses, including Dr. Quintin C. Bascos, who conducted the post-mortem examination and confirmed that Aguilar died from stab ...

Facts:

Incident Details

• On January 31, 1993, at around 5:30 PM, in sitio Pananlaya-an, barangay Datagon, Pamplona, Negros Oriental, appellant Gario Alba stabbed Ricky Aguilar, resulting in his death.
• The victim suffered two stab wounds: one at the back (6 cm) and one at the front (2 cm), which caused massive bleeding and led to his death.

Prosecution’s Version

• Dr. Quintin Bascos conducted the autopsy and confirmed the cause of death as massive bleeding due to injuries to the right kidney artery and right lung.
• Esterlito AniAon, a friend of the victim, testified that he and Aguilar were drinking at a store when Alba suddenly stabbed Aguilar from behind without provocation.
• Roland Ybasan, a pedicab driver, corroborated AniAon’s testimony, stating he saw Alba stab Aguilar from behind, with the knife piercing through to the front chest.
• Valentin Aguilar, the victim’s father, testified about the expenses incurred for the victim’s wake and burial.

Defense’s Version

• Gario Alba claimed self-defense, stating that Aguilar boxed him and attempted to pull out a knife, prompting him to stab Aguilar twice.
• Ricardo Imbo, a laborer, testified that he saw Aguilar punch Alba, after which Alba stabbed Aguilar.
• Wilfredo Jabar Rodriguez, a barangay councilman, testified that Alba surrendered to him after the incident.

Trial Court Decision

• The trial court convicted Alba of murder, sentencing him to reclusion perpetua and ordering him to pay damages to the victim’s heirs.

Issue:

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Ruling:

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Ratio:

1. Self-Defense Not Proven: Alba failed to establish the elements of self-defense, particularly unlawful aggression. The prosecution’s witnesses testified that Alba attacked Aguilar from behind without provocation, which was corroborated by the autopsy report.
2. Treachery as Aggravating, Not Qualifying: Treachery was present as the attack was sudden and from behind, ensuring the victim had no chance to defend himself. However, since it was not specifically alleged in the information as a qualifying circumstance, it was treated only as a generic aggravating circumstance.
3. Crime Classification: The crime was reclassified as homicide because treachery was not properly alleged to qualify the killing as murder. The penalty was adjusted accordingly under the Indeterminate Sentence Law.
4. Damages: The Court increased the moral damages to P50,000 in line with prevailing jurisprudence and upheld the exemplary damages of P20,000 due to the presence of an aggravating circumstance.