G.R. No. L-13337 - People vs. Davis

On the night of April 18, 1954, a dance was held at the house of Fortunato Delizo in barrio Gusing Sur, Naguilian, La Union, connected with a prayer ceremony for his deceased son.
Various individuals attended the dance, including members of the Estepa family (Alfredo, his brother Bernardo, and Federico R. Estepa, the latter two serving as musicians).

Alfredo Estepa departed the dance hall at approximately 12:30 a.m., taking the Naguilian-Bagulin road to return home.
About 45 meters from the dance hall, James Davis intercepted Alfredo without warning, pulled out a knife (designated as Exhibit B), and stabbed him in the abdomen.
The deceased, while injured, cried out for help and identified his assailant by name.

Ariston Villanueva and his son Alfredo Villanueva, who were following at a distance, rushed to aid the victim along with other bystanders.
Alfredo Estepa was eventually transported in a jeep to Lorma Hospital in San Fernando, where Dr. Rufino N. Macagba examined him.
Medical observations confirmed a severe abdominal wound with protrusion of intestines, a weak and rapid pulse, and multiple intestinal injuries, leading to his death at 3:30 a.m.

After learning of his brother’s stabbing, Bernardo Estepa pursued Davis along the road, catching up with him about 40 meters from the dance hall.
Bernardo confronted Davis and, in the ensuing struggle, delivered several punches and twisted Davis’s hands, causing fractures. Federico Estepa also intervened, attempting to restrain the conflict.
Davis’s account diverges notably from that of the state witnesses. He alleged that Alfredo Estepa had engaged him first by boxing him when he was merely 7 meters from the dance hall, an assertion inconsistent with the eyewitness reports.
Defense witnesses (Samson Banayat and Danny Banayat) offered alternative narratives, including that Davis had been involved in mutual physical exchanges, which further muddied the factual picture.

James Davis admitted to stabbing Alfredo Estepa but interposed a defense of self-defense.
His version of events changed over time—initially attributing his fall to a blow on his jaw, later to a blow on his side—thereby undermining his credibility.
Additional inconsistencies arose regarding the description and origin of injuries, with medical evidence (e.g., Dr. Isabelo C. Villanueva’s certificate) failing to substantiate Davis’s claim of injuries from a strangulation attempt.

Eyewitnesses, particularly Ariston and Alfredo Villanueva, provided clear and corroborated accounts describing Davis’s unprovoked and sudden attack in a well-illuminated environment (a full moon complemented by fluorescent lamps).
Silvino Calub testified about a prior interaction where Alfredo, in his capacity as a rural policeman, had admonished Davis—adding context to Davis’s alleged motive.
The defense witnesses appeared late in the investigation, their testimonies shifting on material points and further diminishing their credibility.

Whether the testimonies provided by the state witnesses, particularly from the Villanueva family and other credible witnesses, outweigh the inconsistent and shifting narratives of the defense.
How the varying accounts of physical confrontations and the sequence of events affect the determination of the true nature of the encounter.

Whether Davis’s claim of having acted in self-defense is substantiated by clear and convincing evidence, given the ambush-like nature of the attack on Alfredo Estepa.
Whether the injuries and the physical evidence can be reconciled with the claims that Alfredo Estepa initiated the confrontation.

Whether the injuries sustained by Davis could have resulted from Alfredo’s actions or were rather the product of the counteraction by Bernardo Estepa after the stabbing incident.
Evaluating if the defensive injuries attributed to Davis align with the medical findings and eyewitness observations.