G.R. No. 230221 - People vs. Gayon y Ferreras

Background and identities of the parties
Accused-appellant Edgar Gayon y Ferreras (accused-appellant Edgar) and Rodolfo Gayon (Rodolfo) were charged with the crime of Murder for the killing of Leonora Givera (Leonora).
The Information alleged that on or about July 19, 2004 at about 9:40 in the evening, the killing occurred at Brgy. Sulangan, Matnog, Sorsogon, and within the jurisdiction of the trial court.
The Information alleged that accused-appellant Edgar acted with an armed bladed weapon, and that the killing was committed with intent to kill, treachery, and evident premeditation, with conspiracy and confederation, against Leonora, causing mortal wounds and her instantaneous death.
During the incident, Leyden Gayon (Leyden) was in the house where she was conversing with Leonora.

Version of the prosecution at trial
Leyden testified that on July 19, 2004 at around 9:40 p.m., she was in their house in Sulangan, Matnog, Sorsogon.
Leyden testified that her husband is the first cousin of Rodolfo.
Leyden identified accused-appellant Edgar as the son of Rodolfo.
Leyden testified that while she was having a conversation with Leonora, she saw accused-appellant Edgar enter their house.
Leyden testified that accused-appellant Edgar sat on Leonora’s lap and suddenly stabbed Leonora several times.
Leyden stated that she even saw accused-appellant Edgar’s knife embedded on Leonora’s right shoulder.
Leyden testified that after the stabbing, she dragged Leonora inside the house.
Leyden testified that Leonora uttered to her that she was dying.
Leyden testified that accused-appellant Edgar told his father Rodolfo: "Papay we have no more problem because I killed your sister."
The RTC considered the eyewitness testimony of Leyden and found it corroborated by the medical findings of Dr. Rosanna Galeria.

Version of the defense at trial
Rodolfo testified that on July 19, 2004 at about 9:40 p.m., he was in their house along the road in Sulangan, Matnog, Sorsogon.
Rodolfo claimed he was not present at the time of the killing.
Rodolfo testified he was informed by his wife and daughter-in-law the following morning that his son accused-appellant Edgar had killed Leonora.
Rodolfo alleged that his wife and daughter-in-law had a prior altercation about their chickens and he did not know the reason he was implicated.
Accused-appellant Edgar testified that on July 19, 2004, he arrived home from work but his family was not there.
Accused-appellant Edgar testified that he went back on the road where a person named Toti told him that his family was not home because they quarrelled with Leonora at Leyden’s house where they were drinking gin.
Accused-appellant Edgar testified that he asked Leonora what his wife did causing their frequent quarrel.
Accused-appellant Edgar testified that Leonora pointed a knife at him and said that his wife kept on fighting back.
Accused-appellant Edgar testified that during the struggle, he pushed Leonora inside Leyden’s house after he saw Leyden’s husband approaching with something to hit him.
Accused-appellant Edgar testified he did not notice whether the knife caused any injury.
Accused-appellant Edgar testified that after the incident, he left and went back on the road to look for his family.

Proceedings in the trial court
The RTC, Branch 55, Irosin, Sorsogon rendered a Decision dated October 4, 2012 in Criminal Case No. 1746.
The RTC convicted accused-appellant Edgar of Murder and acquitted Rodolfo.
The RTC sentenced accused-appellant Edgar to Reclusion Perpetua.
The RTC ordered accused-appellant Edgar to indemnify the heirs of Leonora PHP 75,000.00 as civil indemnity and PHP 75,000.00 as moral damages.
The RTC credited the period of detention in accordance with Article 29 of the Revised Penal Code (RPC).
For failure to establish sufficient evidence against Rodolfo, the RTC acquitted Rodolfo and ordered his release if no other case warranted further detention.

Principal issue on criminal liability
Whether the CA erred in affirming accused-appellant Edgar’s conviction for Murder.

Sub-issues on the qualifying circumstances and defenses
Whether the qualifying circumstances of treachery and evident premeditation were proven beyond reasonable doubt to support conviction for Murder.
Whether self-defense was established by cle...(Subscriber-Only)