G.R. No. 167391 - Phil-Ville Development and Housing Corp. vs. Bonifacio

The case arises from an appeal by Wilson Roman, the accused-appellant, from a decision rendered by the Regional Trial Court (RTC) of Iriga City, Branch 35, in Criminal Case No. lR-4231, later affirmed with modification by the Court of Appeals (CA) in CA-G.R. CR-H.C. No. 03972.
The RTC initially rendered its decision on June 10, 2009, and the CA issued its Decision on February 28, 2011. The appeal before the Supreme Court was filed on March 10, 2011 through the Public Attorney’s Office.

On November 11, 1996, Wilson Roman was charged with the crime of murder against Vicente Indaya.
Upon arraignment on February 6, 2004, Roman pleaded not guilty.
The incident occurred on June 22, 1995, during a wedding reception in Barangay Coguit, Balatan, Camarines Sur.
According to multiple eyewitness testimonies, the victim was attacked by the accused with a bolo, sustaining multiple hack wounds.

Elena Romero testified that she witnessed Roman hacking the victim unrelentingly with a bolo at various parts of the victim’s head and body.
Martin Borlagdatan testified that while at the wedding, he saw the victim lying in a pool of blood with the accused standing over him holding a bolo and that an altercation ensued when he tried to intervene.
Asterio Ebuenga and Ramil Baylon corroborated Borlagdatan’s account by testifying that they were in close proximity during the incident and describing the manner in which the bolo was wielded from behind.
Elisea Indaya, the victim’s wife, confirmed the brutal nature of the attack and detailed the repercussions suffered by the victim’s family, who depended on him as the primary breadwinner for eleven children.
Dr. Teodora Pornillos, interpreting the necropsy report prepared by Dr. Mario BaAal, confirmed that the victim sustained seven hack wounds, predominantly at the back of the head, neck, and left shoulder, consistent with an attack from behind.

Wilson Roman testified that he went to his parents-in-law’s house to fetch bamboos and later attended the wedding at the insistence of a friend, Abundio Belbis.
According to his account, while attempting to pacify a dispute between the victim and the victim’s brother-in-law, he heard a warning from a witness (later identified as Delia Tampoco) that “Wilson, you will be hacked!”
Roman claimed that the victim suddenly attacked him with a bolo, prompting him to pull his own bolo from his scabbard and hack in self-defense.
Delia Tampoco testified corroboratively that she observed the sequence where the victim, after issuing a threat, lunged at Roman, who then managed to seize the bolo and retaliate.

The RTC convicted Wilson Roman of murder beyond reasonable doubt.
It found that the evidence—particularly the consistent and categorical testimonies of multiple eyewitnesses—established both the identity of the accused and the qualifying circumstance of treachery.
The RTC rejected the accused’s plea of self-defense, finding that the overwhelming evidence pointed to his initiation of the deadly attack rather than a defensive action.
The RTC imposed a penalty of imprisonment “from twenty years and one day to forty years of reclusion perpetua” and ordered the payment of civil indemnity, actual, and moral damages to the heirs of the victim.

The CA affirmed the RTC’s conviction finding the accused guilty beyond reasonable doubt for the crime of murder.
The appellate court dismissed the plea of self-defense, noting that the evidence showed Roman as the unlawful aggressor.
The CA modified the damage awards by reducing the civil indemnity from ₱100,000.00 to ₱50,000.00, deleting the award for actual damages, and instead awarding ₱25,000.00 as temperate damages plus ₱30,000.00 as exemplary damages.

Whether the accused-appellant could properly invoke the defense of self-defense.
Whether the evidence sufficiently established an instance of unlawful aggression by the victim that would justify the accused’s use of lethal force.

Whether the manner and method of the accused’s attack amounted to treachery.
Whether the accused’s deliberate action of attacking the victim from behind, thereby depriving the victim of any opportunity to defend himself, was proven beyond reasonable doubt.