Facts:

• The case involves the People of the Philippines as the plaintiff-appellee and Gumercindo Quilaton y Ebarola as the defendant-appellant.
• On August 16, 1983, in San Simon, Pampanga, Quilaton, a laborer at the Bureau of Forest Development, fatally stabbed Rolando Manahan, the officer-in-charge of the PROFEM Nursery.
• The incident began when Manahan reprimanded Quilaton for sleeping in the office and bringing women there, leading to a heated argument.
• Quilaton left the office, and Manahan followed him to ensure he left the premises, continuing the confrontation on the provincial road.
• Quilaton stabbed Manahan with a fan knife during this confrontation.
• The trial court found Quilaton guilty of murder and sentenced him to reclusion perpetua, also ordering him to pay various damages to Manahan's heirs.
• Quilaton appealed, arguing self-defense and disputing the presence of treachery.

Issue:

• (Unlock)

Ruling:

1. The trial court did not err in its findings.
2. The killing was not qualified by treachery.
3. The accu...(Unlock)

Ratio:

• The Supreme Court upheld the trial court's findings on the credibility of witnesses, particularly the testimony of Lamberto Abugan, who witnessed the initial stages of the confrontation.
• The Court found no compelling reason to depart from the trial court's assessment.
• The Court agreed with the Solicitor General that Quilaton should be convicted of homicide, not murder, as the prosecution failed to prove treachery.
• Treachery requires evidence of the mode of attack, which was not sufficiently established.
• The heated argument preceding the attack indicated that Manahan was aware of the potential for violence, negating the element of surprise essential for treachery.
• Regarding self-defense, the Court noted that Quilaton's claim lacked corroborative evidence and was inconsistent with the physical evidence and witness testimonies.
• By invoking self-defense, Quilaton admitted to the killing but failed to prove the requisite elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation.
• The Court modified the damages awarded by the trial court:
  • Indemnity for death was reduced to P50,000.00...continue reading