G.R. No. 180512 - People vs. Cuasay

The case originated from an information charging accused-appellant Noel Cuasay with the crime of murder.
It was alleged that on or about October 15, 1997, at around 1:00 a.m. in Barangay Estrella, Municipality of Naujan, Oriental Mindoro, Cuasay, with deliberate intent and using treachery, attacked and stabbed Eduardo Ansuli (alias "Eddie Ansuli") with a sharp-pointed instrument.
The stabbing, which struck Ansuli on the right breast and proved fatal due to profuse hemorrhage, was characterized by its suddenness and the victim’s unpreparedness.
The crime was charged as murder qualified by treachery, signifying the use of means or methods that insured its execution without risk to the offender.

Rizon Reyes, a councilperson and eyewitness, testified that during a mahjong game at the wake of Rosalina Petalpo, he observed Cuasay positioning himself to stab Ansuli and tried to warn with “huwag” before the attack.
Other witnesses, including Flor Paglinawan (also a councilperson), corroborated that Cuasay admitted to stabbing the victim while they were on the terrace of the barangay captain’s house.
Leonila Ilagan, a public health nurse, testified on the necropsy report confirming that a stab wound causing profuse hemorrhage led to the victim’s demise.
With the exception of the testimony by the victim’s mother (admitted by the defense), the prosecution’s evidence did not address any civil aspect beyond establishing the facts of the fatal stabbing.

Accused-appellant pleaded “not guilty” and raised a defense of self-defense.
He claimed that the victim, in an act of aggression—boxing him three times and verbally abusing him—prompted his use of a fan knife.
The accused further argued that the circumstances might also support a conviction for homicide instead of murder, invoking the mitigating circumstance of passion or obfuscation.
Notably, his version rested solely on his own testimony, which conflicted with the more convincing and corroborated account of the prosecution witnesses.

On March 13, 2003, the Regional Trial Court (RTC) rendered a decision finding Cuasay guilty beyond reasonable doubt of murder qualified by treachery.
The RTC sentenced him to reclusion perpetua and ordered indemnification to the heirs of the victim, including awards for actual damages, civil indemnity, and moral and exemplary damages.
The judgment provided for a complex computation of damages and a credit for preventive imprisonment, subject to conditions regarding the accused’s compliance with disciplinary rules.

The case was elevated on appeal, and on July 31, 2007, the Court of Appeals (CA) affirmed, with modification, the RTC’s decision.
On appeal, Cuasay contended that his killing was in self-defense or, alternatively, that the circumstances should reduce the charge to homicide due to passion or obfuscation.
The CA, however, found that Cuasay’s sole reliance on his testimony regarding an alleged act of aggression by the victim was not credible, especially given the consistency of the prosecution’s evidence.
The CA observed that treachery was present because the attack was unanticipated and executed against a defenseless victim.
In awarding damages, the CA retained exemplary damages but deleted the award for moral damages, citing insufficient evidence for the latter.

On appeal before the Supreme Court, the accused assigned errors, arguing that the CA failed to consider the justifying circumstance of self-defense and the mitigating circumstance of passion or obfuscation.
He also contended that the appraisal of the qualifying circumstance of treachery was incorrect.
Ultimately, the Supreme Court found that the burden of proof for self-defense rested on the accused, who failed to provide credible supporting evidence.
While upholding the findings regarding treachery, the Court modified the award by affirming the conviction and ordering the payment of PhP 50,000 as moral damages to the victim’s heirs.
The Supreme Court denied the accused’s appeal, thereby affirming the trial and appellate courts’ decisions with the noted modification.

Whether Cuasay’s claim of self-defense was sufficiently supported by credible evidence.

Whether the testimony provided by the accused could plausibly establish an act of aggression by the victim.
The requirement for corroboration from other witnesses to sustain the self-defense claim.

Whether the mitigating circumstance of passion or obfuscation could be applied.

Whether there was any demonstrable act on the part of the victim that could have incited such a state in the accused.
The temporal proximity between the alleged aggression and the commission of the crime.

The determination if the method of attack indeed ensured the execution of the criminal act without risk to the offender.
The evaluation of whether the suddenness and surprise element of the attack constituted treachery.

The appropriate measure of damages considering the inherent suffering of the victim’s heirs.
The evidentiary requirements (or lack thereof) for granting moral damages in murder cases.