G.R. No. 99355 - People vs. Salazar y Seroma

The case involves the People of the Philippine Islands versus Fermin Marasigan, charged with homicide for the killing of Pedro de Chavez.
The incident took place on March 24, 1927, in the barrio of Mangalang, municipality of Sariaya, in the Province of Tayabas.
The charge stemmed from an alleged act committed by Marasigan, whereby he, armed with an edged weapon and a club, inflicted multiple wounds on the deceased that were identified as necessarily fatal.

The backdrop of the incident was a feast at Agapito de Silva's house, held on the occasion of the baptism of one of his children.
Both the accused and the deceased were present at the gathering.
The deceased offered the accused a cup of wine, which Marasigan declined citing his earlier consumption during the meal and his habitual restraint from drinking excessively.
The refusal was interpreted by the deceased as a personal slight, provoking a verbal exchange that escalated tensions among the guests.

After declining to drink further and excusing himself from the gathering, Marasigan was observed preparing to leave by retrieving his hat and subsequently arming himself with a penknife and picking up a club.
The deceased, Pedro de Chavez, who had also consumed wine and exhibited signs of being flushed, followed Marasigan shortly after.
With a distance of about 5 brazas between them on the street, the two engaged in physical combat.
During the confrontational encounter:

Marasigan struck Pedro de Chavez with the club as the latter caught up with him.
A fist fight ensued which escalated when Marasigan stabbed the deceased multiple times with his penknife.

Both combatants fell to the ground; after getting up and separating, the deceased, while moving away, collapsed and died shortly thereafter.
The wounds on the deceased—ranging from chest and abdominal stab wounds to cuts on the neck, forearm, and facial bruises—were corroborated by the examination of the body by local health officials.

The prosecution presented the testimonies of three eyewitnesses: Agapito de Silva, Casimiro de Chavez, and Juan Resurreccion, who collectively attested to the sequence of events during the altercation.
The defense argued that additional eyewitnesses, namely disinterested persons, were not summoned, suggesting that their omission could have been favorable to the resolution of the case.
The trial court, however, found that the evidence presented was sufficient to support the occurrence of the fatal act and found inconsistencies in the defense’s assertions.

Fermin Marasigan claimed that the deceased initiated the aggression by producing an affront when Marasigan declined the wine.
He argued that his actions were executed in self-defense in response to an attack by the deceased.
The defense maintained that:

The deceased was known for his aggressive demeanor, having a reputation as a bully with criminal antecedents.
Marasigan himself had a good reputation and no prior criminal record.
His state during the event did not reflect an intention to commit homicide but rather a reaction to an unjustified provocation.

Whether the trial court erred in relying on the testimony of only three eyewitnesses while omitting others whom the prosecution acknowledged as having witnessed the incident.
Whether the omission of additional cumulative eyewitness evidence can be taken as prejudicial to the prosecution’s case.

Whether the facts proved that the aggression originated with the deceased rather than being unprovoked on the part of Marasigan.
Whether the evidence of the deceased’s aggressive reputation and physical strength outweighs the defendant’s claim of having acted in self-defense.

Whether the circumstances under which the altercation commenced can justify a plea of self-defense by Marasigan.
Whether the conduct of both parties, especially the mutual engagement in the fight, excludes the applicability of self-defense as recognized in previous jurisprudence.

Whether the failure to present all possible eyewitness testimonies creates a presumption that the suppressed evidence would have been unfavorable to the prosecution.
How the principle from United States vs. Gonzalez applies to the sufficiency of cumulative evidence in proving the occurrence of the alleged act.