G.R. No. 127815 - People vs. Santillana

The accused-appellant, Stephen Santillana y Sarad, was charged with murder under Criminal Case No. 94-0906 stemming from an incident on October 30, 1994.
The offense took place in ParaAaque, Metro Manila, where, allegedly with intent to kill, treachery, and evident premeditation, Santillana attacked and stabbed Wilfredo Limpiado, resulting in the latter’s death.
At arraignment on December 1, 1994, Santillana pleaded not guilty.

Santillana and his co-boarder, Mario Bacamante, were reportedly fixing a sink at the second floor of their rented house at Sitio Pagkakaisa when a dispute with Teresita Limpiado, a neighbor, emerged regarding the installation obstructing the Limpiado household’s plans.
In response to Teresita’s objection, Santillana claimed that he had the permission of the owner to proceed, and continued the work.
Following the confrontation by Teresita, Santillana went to his second floor to retrieve a knife and some wires, then returned to the ground floor.
As the events unfolded, Wilfredo Limpiado, Teresita’s husband, emerged from his dwelling and, after inquiring about the disturbance, requested Bacamante to halt the installation work.
After multiple requests, Santillana immediately stabbed Wilfredo with the knife resulting in a fatal wound; subsequent post-mortem findings confirmed death due to hemorrhage from a stab wound in the abdomen.
Law enforcement testimonies, including those of SPO1 Moises Bernal and SPO1 Renato Lumapat, confirmed that Santillana surrendered himself after the incident, having reportedly discarded the weapon used in the stabbing.

Santillana and Bacamante had agreed to install a waterspout and sink to aid his wife, Marilou, who faced difficulties with water supply; the work was done with the landlord’s consent.
During the installation, Teresita confronted Santillana with loud objections and insults.
Santillana maintained that while fetching a knife to cut wires necessary for the installation, he was unexpectedly confronted by Wilfredo Limpiado who lunged at him.
Citing self-defense, he argued that he acted solely to protect himself from an unanticipated armed attack, asserting that his actions were accidental, unpremeditated, and devoid of a deliberate intent to kill.
The defense further pleaded mitigating circumstances, including voluntary surrender and praeter intentionem (lack of intent to commit a grave wrong).

Testimonies of key witnesses such as Teresita Limpiado, Gary Miano (eyewitness), and police officers were crucial.
Discrepancies emerged regarding the presence and actions of other persons near the scene, as well as the direction of the stab wound and the hand used in the stabbing (the accused was noted to be left-handed despite testimony suggesting otherwise).
The medical report confirmed that the stab wound was severe, cutting vital structures (7th rib, diaphragm, and penetrating the liver), thereby ensuring a fatal outcome.
The trial record indicated that, despite the defense’s self-defense claim, the evidence pointed to an excessive and deliberate use of force.

Whether the trial court erred in holding that the act committed by Santillana was qualified by intent to kill and treachery.

The accused argued that there was no premeditation and that he encountered the victim by chance, hence lacking the necessary design to kill.
Discrepancies in eyewitness testimonies regarding the mode of the attack (e.g., the hand used in the stabbing) were raised.

Whether the trial court failed to appreciate the mitigating circumstances, particularly the voluntary surrender and praeter intentionem.

Santillana contended that his actions post-incident, including calling for police assistance and his demeanor, demonstrated an absence of malice.
The defense maintained that the act was accidental and unintentional and should thus be mitigated.

Whether the trial court erred in not fully appreciating the justifying circumstance of self-defense or, at the least, incomplete self-defense.

The accused asserted that all requisites of self-defense were present, including an immediate threat from the victim, a lack of room to retreat, and the use of reasonable force.
The court had to evaluate whether the force used was truly necessary or if it represented an excess beyond self-defense.