G.R. No. 152604 - People vs. Pedrigal

The accused, Leoncio Pedrigal y Simballana, known as “Bakla,” was charged with murder in Criminal Case No. 5247-G before the Regional Trial Court (RTC) of Gumaca, Quezon, Branch 61.
The incident occurred on or about December 18, 1995, in Sitio Badajos, Barangay Butanyog, Municipality of Mulanay, Province of Quezon.

Prior to the incident, a conversation was overheard wherein Juana Pedrigal allegedly told her son, “Bakla, parang awa mo na, tulungan mo si Pepe at nilolooban ni Ricky,” suggesting a motive linked to familial sentiments and a supposed wrongdoing committed by the victim.
Later that afternoon, Crisanta Carsola, who was having coffee and conversing with others including the victim Ricky NapeAas and Leonora Rejano, witnessed the sudden appearance of the appellant.
The accused, emerging from the dark, attacked Ricky NapeAas by repeatedly stabbing him using a small bolo (itak-itakan).
Barangay Captain Felino Rosas and Carsola intervened; they disarmed the accused and rushed the victim to a hospital, although the victim eventually expired en route.
An autopsy conducted by Dr. Heriberto Morales confirmed that the victim died of hemorrhagic shock due to multifarious wounds, with the fatal wound being on the abdomen, leading to the small intestine spilling out.

The appellant denied the charge of murder, asserting that he acted in self-defense after being stabbed by NapeAas with an ice-pick during a confrontation.
He admitted to drawing his bolo and engaging in a fight that allegedly lasted about thirty minutes, after which both parties were exhausted.
The evidence he presented included a medical certificate issued at a hospital in Catanauan; however, the document remained in his parents’ possession.

The prosecution contended that the appellant attacked with treachery, as he launched a sudden and premeditated assault that left the victim no opportunity to defend himself.
Multiple witness testimonies, including those from public officials (Barangay Captain Rosas and Barangay Kagawad Carsola), confirmed the identity of the accused and the circumstances of the attack.
The number, nature, and location of the stab wounds (totaling seven, with one being fatal) were used to illustrate the deliberate intent to kill rather than a mere act of self-defense.
The evidence also emphasized that the accused’s method of tying the bolo to his jacket long sleeve ensured he was not exposed to any retaliatory action, underscoring the element of treachery.

The trial court found the accused guilty beyond reasonable doubt of murder under Article 248 of the Revised Penal Code and sentenced him to reclusion perpetua.
The court also ordered the payment of P50,000.00 as civil indemnity, P20,000.00 as actual damages, in addition to costs of the suit.
Despite the appellant’s claim of self-defense and contention for a conviction of homicide instead of murder, the trial court gave full credence to the witnesses’ testimonies and the physical evidences which pointed to a deliberate and treacherous attack.

Whether the appellant could validly assert self-defense given his admission that he killed the victim.
Whether the requisite elements of self-defense—non-aggressor status, lack of sufficient provocation, and the employment of reasonable means to repel aggression—were established.

Whether the accused’s actions, characterized by multiple and fatal stab wounds, qualify as murder (with treachery) rather than a lesser offense such as homicide.
Whether the suddenness and unexpected manner of the attack constitute treachery, ensuring the assailant’s protection against any form of retaliation by the victim.