Title
People vs. Belaje
Case
G.R. No. 125331
Decision Date
Nov 23, 2000
Belaje convicted of homicide, not murder, after stabbing Bonifacio Caysido in 1994. Claimed self-defense; court found insufficient evidence, recognized voluntary surrender, imposed reduced penalty, and awarded damages.

Case Digest (G.R. No. 125331)

Facts:

People of the Philippines v. Merlindo Belaje, G.R. No. 125331, November 23, 2000, Supreme Court First Division, Kapunan, J., writing for the Court. The appeal challenges the Regional Trial Court (RTC) of Tacloban City, Branch 8 (presided by Judge Walerico B. Butalid), Decision in Criminal Case No. 94-12-524 that convicted Merlindo Belaje of murder and sentenced him to reclusion perpetua.

The information charged that on or about June 24, 1994 in Babatngon, Leyte, appellant, with deliberate intent and by means of treachery and evident premeditation, stabbed Bonifacio Caysido with a pisaw, inflicting fatal wounds. At arraignment appellant pleaded not guilty. At trial the prosecution presented two witnesses: Rogelio Caysido (the victim’s son) testified he saw appellant stab his father at their house that evening and that the victim later died in hospital after eleven days; Victoria Caysido (the victim’s wife) testified she learned that her husband had been stabbed in the yard and quantified moral damages and hospital expenses, but admitted she did not personally witness the stabbing. The medico-legal report (admitted without objection) showed a thoraco‑abdominal stab wound with injuries to diaphragm, pancreas tail, colon and stomach, and that the victim “expired intra operative” on July 5, 1994.

Appellant testified in his own defense, admitting he stabbed the victim but claiming self-defense: he said he approached the Caysidos to ask that their karaoke be turned down, was slapped by the victim, then grappled with the victim’s son Danilo Joseph who drew a knife; appellant claimed he wrested Joseph’s knife after a five‑minute struggle, that the victim then drew his own knife and lunged at him, and that he stabbed the victim to repel the attack. Appellant stated he surrendered to authorities the same night and was detained briefly. The trial court discredited his self‑defense claim as uncorroborated and incredible, convicted him of murder but appreciated voluntary surrender as mitigating, imposed reclusion perpetua, and awarded P50,000.00 moral damages, P80,000.00 reimbursement for hospital expenses, P50,000.00 indemnity, and costs.

Appellant appealed to the Supreme Court, assigning error to the conviction for murder and to the trial court’s rejection of his claim of unlawful aggression/self‑defense. The Solicitor General argued the prosecution h...(Subscriber-Only)

Issues:

  • Did the trial court err in finding the accused‑appellant guilty beyond reasonable doubt of the crime of murder?
  • Did the trial court err in holding that the accused‑appellant failed to prove unlawful aggression and thus rejecting his defense ...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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