G.R. No. 226392 - People vs. Caliao

An Information was filed on 20 August 2004 charging Nestor "Tony" Caliao with murder.
Despite the Information’s filing, Caliao was only arrested on 6 September 2010.
Upon arraignment, Caliao pleaded not guilty, leading to the ensuing trial.

Incident occurred on or about 25 April 2004 in Cebu City, within the jurisdiction of the court.
Caliao, allegedly armed with a kitchen knife, attacked and stabbed William A. Fuentes, causing injuries that led to the victim’s death a day later.
The attack was characterized by deliberate intent, use of treachery, and evident premeditation, according to the prosecution’s version.

Witnesses included Virginia Fuentes (victim’s wife), Junnel Fuentes (victim’s son), and market vendors Maximo Largo and Ricardo Tesorio.
Events leading up to the crime:

On the night of 24 April 2004, an altercation occurred when Caliao allegedly placed garbage beside the Fuentes’ store, prompting confrontation and a subsequent attempted assault involving a pipe.
In the early hours of 25 April 2004, after initial hostilities, the victim experienced further harassment including the puncturing of his bicycle’s tires.

On the afternoon of 25 April 2004, while Virginia was asleep inside the store and the victim was outside, Caliao suddenly appeared and stabbed William Fuentes.
As the victim sought refuge inside the store, Caliao allegedly followed him and attempted a second attack while shouting threats.
Intervention occurred when Racel Caliao, the accused’s wife, was alerted by market vendor Ricardo Tesorio and pulled Caliao away, while others secured the bloodied knife and turned him over to the police.

Caliao, along with Roberto Oralde and George Cabino, testified that the incident was an act of self-defense.
According to Caliao’s account:

He was preparing pusA3 (a local term for hanging rice) for delivery when the victim unexpectedly appeared and poured kerosene on the pusA3.
The victim then allegedly brandished an iron pipe and struck Caliao repeatedly, cornering him.
In response, Caliao picked up a kitchen knife and struck the victim before retreating to his home.

Roberto Oralde corroborated this version by testifying that he saw the victim attack Caliao with a pipe and noted the presence of kerosene brought into the store.
The prosecution, however, introduced rebuttal evidence via Belinda Ligan, who contradicted Roberto’s claim regarding his longstanding association with Caliao’s mother and his presence around the market.

The Regional Trial Court (RTC) found sufficient evidence to convict Caliao beyond reasonable doubt of murder, citing the lack of a clearly established self-defense claim.
In its decision, the RTC noted the aggravating circumstances of treachery and evident premeditation, and sentenced Caliao to reclusion perpetua, also ordering him to pay various forms of damages (civil indemnity, moral, temperate, and exemplary).
On appeal, the Court of Appeals (CA) affirmed the RTC’s conviction but modified certain findings:

While treachery was still recognized as qualifying for murder, the element of evident premeditation was deleted because the evidence did not show that Caliao had a fixed determination to kill the victim.
The CA increased the amounts for civil indemnity and moral damages and adjusted the award for exemplary damages.

Caliao contended that he had sufficiently established all elements of self-defense, thus justifying his actions.
He further argued that the prosecution’s narrative was unreliable on account of alleged bias on the part of the victim’s relatives, who were expected to be hostile towards him.

Whether the proving of Caliao’s guilt for murder (or homicide) has been established beyond reasonable doubt.
Whether the accused successfully established the elements of self-defense with clear and convincing evidence.
Whether the aggravating circumstances—specifically treachery and evident premeditation—were correctly applied to elevate the crime to murder in the trial court’s decision.