G.R. No. 99259-60 - People vs. Santos y Delgado

The appellant, Emilio Santos V Delgado, was convicted for two separate crimes: the murder of Valentino Guevarra and the frustrated murder of Francisco Lacsa.
The Regional Trial Court of Manila imposed the penalties of reclusion perpetua (with accessory penalties) for murder and an indeterminate penalty for frustrated murder, along with the payment of actual and moral damages to the respective victims’ kin.

On the evening of October 22, 1989, Francisco Lacsa was abruptly awakened by his close friend and compadre, Valentino Guevarra, who appeared in a torn, bloodstained shirt.
Valentino informed Francisco of a prior misunderstanding with Emmanuel Santos, the father of the accused, which had created tension that evening.
Francisco, acting in his capacity as a Barangay Tanod and knowing Emmanuel personally, agreed to accompany Valentino to settle the dispute.

Upon reaching the house of Emmanuel Santos, Francisco and Valentino were met with hostility as Emmanuel, accompanied by his daughter Elizabeth, confronted them with a bow and arrow.
Fearing for their lives, Francisco and Valentino retreated and ran towards the corner of Laong-Laan and Dela Fuente Streets.
At about fifty (50) meters into their escape, a tricycle carrying the accused, his brother Dionisio, and two unidentified individuals intercepted the fleeing pair.

The attackers, including the appellant who wielded a samurai sword, along with his cohorts, launched a concerted assault on Valentino and Francisco.
Dionisio, armed with a jungle bolo, attacked Valentino, while the appellant repeatedly stabbed and hacked Valentino, resulting in fatal injuries.
Francisco was also attacked: his left hand lost four fingers, and he sustained multiple stab wounds, though he survived by fleeing to a nearby transportation compound and later receiving medical attention.

The prosecution, relying on Francisco Lacsa’s testimony, established a narrative that implicated the appellant in the brutal assault.
The appellant admitted to stabbing Francisco but claimed that his actions were in self-defense and in avenging the assault on his father.
The incident details were supported by physical evidence, including the severity and multiplicity of wounds on both victims, which cast doubt on any reasonable self-defense claim.

The accused did not dispute his conviction per se but instead raised issues on appeal regarding the failure to consider:

The ordinary mitigating circumstance of immediate vindication of a grave offense committed against an ascendant.
The privileged mitigating circumstance of incomplete defense of a relative.

The appellant’s version of events asserted that upon learning from his uncle about an earlier physical altercation involving his father, he armed himself and awaited an imminent attack.
However, evidence and testimonies contradicted his account:

The trial court and prosecution established that the alleged aggression against his father had already ceased by the time the appellant confronted Francisco and Valentino.
The testimonial inconsistencies, particularly regarding his location at the time of his father’s assault and the subsequent delay in his response, undermined his claims.

The trial court found the prosecution’s chain of evidence more credible and accepted Francisco Lacsa’s account.
It ruled that the mitigating circumstances claimed by the appellant were untenable because:

The conditions for self-defense (i.e., absence of provocation and continuation of unlawful aggression) were not met.
The physical evidence (the excessive number and severity of wounds) indicated a deliberate, disproportionate use of violence rather than a mere act of defense or incomplete defense.

Consequently, the court affirmed the imposition of penalties for both murder and frustrated murder.

Whether the facts and testimonies sufficiently negated the elements of self-defense claimed by the appellant.
Whether the prosecution’s evidence establishing the cessation of unlawful aggression was conclusive in discrediting the self-defense assertion.

Whether the ordinary mitigating circumstance of immediate vindication of a grave offense against an ascendant could apply given the elapsed time and the sequence of events.
Whether the privileged mitigating circumstance of incomplete defense of a relative was established, particularly in the absence of demonstrable unlawful aggression by the victims.

Whether the extent and severity of the force used (multiple stabbings and hacks) were consistent with a genuine act of defense.
Whether the disproportionality of the response invalidated any claim of mitigation on the part of the accused.

How the credibility and inconsistencies in the appellant’s version of events affected the overall assessment of his mitigating defenses.
Whether the timeline of events supported or contradicted the assertion of immediate vindication and incomplete defense.