G.R. No. 71510 - People vs. Silfavan

The case involves the People of the Philippines versus Roderick R. Ramelo.
The accused was originally charged with murder, with the Regional Trial Court (RTC) finding him guilty beyond reasonable doubt, and the Court of Appeals (CA) later modifying the conviction to homicide.

The crime occurred on or about May 17, 2009, in Baybay City, Leyte, at around 1:55 a.m.
The victim, Nelson PeAa, was attacked while standing outside a basketball court being used as a venue for a dancing event.
Ramelo allegedly approached Nelson, suddenly stabbing him with a kitchen knife—a weapon reportedly provided by Ramelo himself.
The nature of the attack was described as treacherous, as it was sudden and without warning, leaving the victim no chance to defend himself.

Four prosecution witnesses testified: Barangay Captain Gilberta Ortega, Barangay Tanod Samuel Vega, Nelson’s father Alfredo PeAa, and Dr. Nelson Udtujan.
Witnesses established that Ramelo appeared suddenly and attacked Nelson with evident premeditation and treachery.
Samuel Vega’s testimony provided that he confronted the assailant, confiscated the weapon, and turned it over to law enforcement, thereby substantiating the account of the stabbing.
The post-mortem report by Dr. Udtujan confirmed an eight-centimeter deep stab wound on the left upper quadrant of Nelson’s abdomen, which injured internal organs and led to massive bleeding and death.

Roderick Ramelo and Rey Pilapil testified in support of a self-defense claim.
Ramelo’s version stated that on the night of May 16, 2009, while he was at a store near the dancing hall, he witnessed Nelson engaged in a drinking spree with companions.
He claimed that after being unexpectedly slapped by one of Nelson’s companions (Naji), a physical scuffle erupted between him and a group that included Nelson.
According to Ramelo, Nelson then approached him aggressively—grabbing him by the collar, strangling him, and continuing the assault together with his companions.
Ramelo contended that, fearing for his life as he was outnumbered (claiming that seven persons were involved), he resorted to drawing a concealed knife (hidden in his right shoe) and stabbed Nelson.

Immediately after the stabbing, Ramelo handed his knife to Pilapil, who in turn gave it to Samuel Vega.
Approximately nine hours later, on May 17, 2009, Ramelo voluntarily surrendered to the Philippine National Police in Baybay City.

The RTC found Ramelo guilty beyond reasonable doubt of murder.
The court was unpersuaded by Ramelo’s self-defense claim, noting discrepancies in his testimony compared to that of his co-accused witness, Pilapil.
The trial court emphasized that no unlawful aggression was shown on Nelson’s part and that the attack was characterized by treachery due to the manner of the stabbing.
Ramelo was sentenced to reclusion perpetua, with additional civil indemnity and damages imposed.

The CA affirmed the RTC’s conviction with modifications.
It agreed that the self-defense claim was unsubstantiated, primarily because Pilapil’s account did not corroborate Ramelo’s version and indicated that any confrontation had ceased before the stabbing occurred.
The CA modified the conviction from murder to homicide, noting that the element of treachery was not sufficiently established.
Mitigating circumstances, specifically Ramelo’s voluntary surrender, were credited, resulting in a penalty ranging from eight (8) years and one (1) day of prision mayor as a minimum to fourteen (14) years of reclusion temporal as a maximum.

Whether the trial and appellate courts erred in not appreciating the justifying circumstance of self-defense presented by Ramelo.

Specifically, the issue was whether the evidence was sufficient to establish that Nelson’s alleged aggression justified Ramelo’s use of deadly force.