Facts:

• Alberto Macaso, a patrolman in the Basilan City Police Department, was convicted of murder.
• The incident took place on October 19, 1964, involving the victim, Nicolas Suaso, a former detective corporal.
• Macaso confronted Suaso for parking in a prohibited area at the wharf, which escalated into a heated argument.
• Suaso disrespected Macaso and challenged his authority, refusing to comply with his orders.
• During the confrontation, Suaso allegedly attempted to grab Macaso's service pistol.
• Macaso shot Suaso multiple times, leading to the victim's death from internal hemorrhage.
• The trial court found Macaso guilty of murder, citing treachery and evident premeditation as aggravating circumstances.
• Macaso appealed, asserting self-defense and disputing the trial court's findings.

Issue:

• (Unlock)

Ruling:

• The Supreme Court determined that the trial court erred in finding treachery and evident premeditation.
• The conviction was modified from murder to homicide due to insufficient evidence for the aggravating circumstances.
• Although self-defense was not successfully claimed, the Court imposed a p...(Unlock)

Ratio:

• For a valid self-defense claim, three elements must be present:
  • Unlawful aggression by the victim.
  • Reasonable necessity of the means employed to repel the aggression.
  • Lack of sufficient provocation by the accused.
• The Court found that Suaso's disrespectful behavior did not constitute unlawful ag...continue reading