G.R. No. 171951 - Garcia vs. People

Accused-appellant Gerry Nalangan, alias Gerry Bukol, was adjudged guilty by the Regional Trial Court, Branch 19, Bacoor, Cavite, initially for the crime of murder in Criminal Case No. B-89-93.
The appellant subsequently raised his appeal, basing his recourse on the assertion of self-defense and on challenging the reliability and credibility of the prosecution witnesses.

The criminal information dated March 9, 1989, specifically alleged that on or about 11:30 p.m. of February 28, 1988, at the vicinity of Block 14 and 15, Barangay Ramon Cruz, Municipality of General Mariano Alvarez, Cavite, the accused, being then armed with a kitchen knife, intentionally attacked the victim, Emmanuel Rosal.
It was alleged that the accused, with intent to kill and employing treachery and evident premeditation, stabbed the victim in the stomach, inflicting a mortal wound that eventually caused the death of Emmanuel Rosal.

At his arraignment, the appellant registered a negative plea with the assistance of counsel.
The trial featured prosecution witnesses including Rogelio Alvarez, Jose Samone, Jr., Constancia Rosal, Pat. Roland Alamo, and Dr. Ruben Maranan, whose testimonies established the sequence of events leading up to and following the stabbing.
The victim was observed to have been attended by his friends, taken to a hospital, and hospitalized for about two weeks before succumbing to the injuries.

Witnesses Rogelio Alvarez and Jose Samone, Jr., who were friends and townmates of both the victim and the accused, testified that after a drinking session with the victim and the accused, they saw the latter running away holding a knife as the victim, having been struck, shouted for help.
Their accounts conveyed that moments before the incident, the accused had intimated his intent to harm the victim, and following the stabbing, the victim insisted that the accused was responsible for the attack.

The accused claimed that the altercation began when the victim attempted to extort P20.00 from him after the appellant had been at a friend’s house watching television.
According to him, the conflict escalated when the victim, after an initial confrontation involving the offer to buy a plastic bag of marijuana, assaulted him with a knife.
The accused recounted that during the ensuing struggle, the victim’s knife fell, and upon retrieving it in an attempt to escape, he was forcefully restrained by the victim, prompting him to stab the victim in self-defense.

The prosecution witnesses, deemed credible and without any indication of ill motive, contradicted the appellant’s narrative by affirming that no scuffle or extortion incident had occurred prior to the stabbing.
Their testimonies corroborated the sequence of events pointing towards a deliberate attack by the appellant, including his flight from the scene.

On November 29, 1993, the court rendered a verdict sentencing the accused to reclusion perpetua, with additional orders to indemnify the victim’s heirs and pay costs.
The appellant’s failure to present corroborated evidence in support of his self-defense claim, coupled with the strong prosecution testimony, shaped the trial court’s findings against him.

The appellant contended that the trial court erred by giving undue weight to the prosecution’s credible testimonies while disregarding his own uncorroborated account.
He argued that the court failed to find evidence of unlawful aggression by the victim and improperly convicted him beyond reasonable doubt despite invoking a self-defense argument.

Whether the trial court erred in giving full credence to the testimony of the prosecution witnesses while dismissing the appellant’s own version of events.
Whether the evidence sufficiently established the elements of treachery and evident premeditation, or, alternatively, whether the act should be qualified as homicide rather than murder.
Whether the appellant's claim of self-defense was adequately proven, considering the requisite elements that must be clearly and convincingly demonstrated.
Whether the appellant’s flight from the scene effectively undermined his claim of self-defense by indicating an absence of immediate danger.