G.R. No. 213273 - People vs. Siega

The accused-appellant, Leonardo B. Siega, was charged with Murder under Article 248 of the Revised Penal Code, as amended, via an Information dated January 25, 2006.
The charge alleged that on October 16, 2005, at around 4:30 p.m., at Sitio Lubong Sapa, Barangay Kahupian, Municipality of Sogod, Southern Leyte, Siega willfully, unlawfully, and feloniously attacked and killed Pacenciano Bitoy using a sharp pointed bolo (locally known as sundang).
The Information emphasized the elements of intent to kill, evident premeditation, treachery, and the resultant instantaneous death of Bitoy, causing damage to his heirs and perturbing social order.

Siega pleaded not guilty and maintained that his actions were in self-defense.
He claimed that as he was about to enter his house, he heard a noise coming from the feeder road and saw Bitoy rushing toward him, allegedly with the intention to engage in a grudge-related confrontation.
Believing Bitoy was preparing to draw a weapon, Siega immediately grabbed a bolo near him and attacked, inflicting several injuries before Bitoy retreated.
After the incident, Siega changed his clothes and surrendered to the authorities.

Emiliano Gildore testified that he was at the back of Siega’s house checking on piglets when he heard a foreign vernacular call suggesting a grudge confrontation.
He observed Bitoy, armed with a bolo, facing Siega and claimed that when Bitoy allegedly reached for his weapon, Siega stabbed Bitoy first.
Gildore’s credibility was later undermined by inconsistencies and apparent bias (having been called by Siega’s uncle to testify).

Melicio Alingasa testified that Bitoy and his friend were walking along the feeder road when Siega, armed with a bolo, suddenly approached and issued a challenge.
Alingasa recounted that Bitoy denied any challenge and later, when Siega suddenly reversed direction to confront Bitoy, he proceeded to stab him on the left side of the chest.
Alingasa observed Siega repeatedly hacking Bitoy even after the latter was down, and he immediately informed Bitoy’s wife about the incident.

The postmortem report by Dr. Lodivico C. Mosot revealed that Bitoy sustained multiple injuries: three deep hack wounds on the face (resulting in the right eyeball being dislodged), two hack wounds on the forearms, and three deep penetrating stab wounds on the chest cavity likely responsible for massive hemorrhage and immediate death.
No weapon was recovered from Bitoy, contradicting Siega’s claim that Bitoy was armed.

The RTC found Siega guilty beyond reasonable doubt of Murder and sentenced him to reclusion perpetua, along with ordering him to pay damages.
The RTC ruled that Siega failed to establish the element of unlawful aggression necessary for a valid claim of self-defense.
The court emphasized that although Siega contended Bitoy was drawing a weapon, no such weapon was found, and Alingasa’s credible testimony established that Bitoy was unarmed.
The RTC discredited the testimony of Gildore due to inconsistencies and bias, in contrast with the straightforward testimony of Alingasa.
While treachery was confirmed based on the facts (sudden, unexpected attack on an unarmed victim), there was no determination of evident premeditation, which affected the nature of the penalty.
The mitigating circumstance of voluntary surrender was also considered in the imposition of the lower penalty.

The CA affirmed the RTC’s conviction with modifications, particularly in the computation of civil and moral damages.
The CA upheld that Siega’s claim of self-defense failed because he did not prove that there was unlawful aggression on Bitoy’s part, citing the absence of any recovered weapon and the credible eyewitness testimony.
The CA reiterated that the presence of treachery—characterized by Siega’s sudden and unexpected attack on an unarmed Bitoy—was sufficient to qualify the killing as Murder.
The CA modified the damages awarded:

Civil indemnity was set at Php 75,000.00.
Moral damages were increased to Php 75,000.00.
Exemplary damages were fixed at Php 75,000.00.
Temperate damages were increased to Php 50,000.00 in lieu of actual damages.
All awards were subject to six percent (6%) per annum interest from the decision’s finality until payment in full.

The CA stressed that regardless of any consideration of alternate accounts, the element of unlawful aggression—the cornerstone of self-defense—was absent, rendering Siega’s claim invalid.

Whether the CA erred in upholding the conviction of Leonardo B. Siega for Murder despite his claim of self-defense.

Whether Siega sufficiently established the required elements of self-defense, namely:

Whether the evidence, particularly the testimony of eyewitnesses (especially Alingasa) and the absence of any recovered weapon, supports the finding of treachery and negates any valid claim of self-defense.
Whether the CA correctly modified the damages award in light of the pertinent legal standards and the evidence on record.