G.R. No. L-40757 - People vs. Macariola

On September 21, 1971, within the New Bilibid Prisons in Muntinlupa, inmate Romeo de la Pena (No. 29820-P) was fatally stabbed inside the confines of Brigade 2-D.
The incident occurred between 8:00 and 9:30 in the morning, with the stabbing taking place in the victim’s cell.
The stabbing involved the use of an improvised weapon known as “matalas” and was witnessed by several inmates (e.g., Romeo Sato, Fernando Gomez, Alvarez, and Severino Pingkian).

A quarrel had ensued stemming from a gambling dispute known as “Hong Chang” and related issues over money, blankets (referred to as “balato”), and pants exchanged between the accused and the victim.
The conflict escalated when, after gambling, the victim snatched money from defendant Ricarte Macariola, resulting in the victim kicking Macariola on the chest.
Following the altercation and the kick, both parties stood up; the accused then drew his “matalas” from his waist and initiated a stabbing assault.
Romeo de la Pena sustained a total of sixteen stab wounds, with two particularly fatal wounds (one involving the left lobe of the liver and left ventricle of the heart, and multiple wounds penetrating the right lung).

Prosecution witnesses, including fellow inmates and prison guards, testified that the stabbing was committed with treachery and occurred despite the victim’s attempts to seek refuge (e.g., by running to a “kubol” or hiding under his “tarima”).
Physical evidence included the recovered weapon (wrapped and identified by an inscription), autopsy findings by Dr. Cristino S. Garcia confirming the fatal nature of the injuries, and consistent statements regarding the number and location of wounds.
The accused admitted to stabbing the victim in his initial investigation statement but later raised a claim of self-defense.
Conflicting versions emerged: while the prosecution maintained that Macariola aggressively stalked and continued to stab the victim (even after the latter was defenseless), the defense argued that the accused acted out of self-defense due to the victim’s initial aggressive act.

Macariola was a prisoner already serving a sentence for robbery, which raised the legal issue of quasi-recidivism under Article 160 of the Revised Penal Code.
Aggravating factors cited included treachery, evident premeditation in the manner of the repeated stabbings, and the accused’s quasi-recidivist status.
Although the defense highlighted provocation (the victim’s kick) as a mitigating circumstance, such provocation was not found to amount to unlawful aggression sufficient to justify self-defense or reduce the charge from murder.

Whether the crime committed by Macariola should be categorized as murder or merely homicide.

The pivotal question was if the killing was attended by treachery and evident premeditation, qualifying it as murder under Article 248 of the Revised Penal Code.

Whether the victim’s initial act of aggression (the kick) constituted sufficient unlawful aggression to justify the use of deadly force in self-defense.

Whether Macariola’s previous conviction for robbery should enhance the penalty applicable to the subsequent offense.

The reconciliation of conflicting testimonies (from the prosecution and defense witnesses) in establishing the facts beyond reasonable doubt.