G.R. No. 124127 - People vs. Solis

On or about October 12, 1994, at around 6:00 p.m., an incident occurred at the Mangaldan Public Market in Mangaldan, Pangasinan.
Accused-appellant Rey Solis was charged with the killing of Eduardo Uligan, which the prosecution alleged was committed with treachery and during a sudden, unexpected assault.
The victim, Eduardo Uligan, was reportedly attacked from behind by Solis, who, armed with a knife (commonly known as a “balisong” or Batangas knife), inflicted a fatal stab wound.
Following the stabbing, the accused immediately fled the scene and later was apprehended in Gapan, Nueva Ecija by police officers assisted by a barangay captain.

Flora Cera, a housewife, testified that she saw Rey Solis approach Eduardo Uligan from behind and stab him after Uligan had been buying from an ambulant vendor.
Cera identified Solis positively in court and detailed the circumstances of the stabbing, including the proximity (approximately 1.5 meters) and the sudden nature of the assault.

Dr. Eugenio De Leon, the attending physician at Medical City Dagupan, testified that the stab wound was fatal and consistent with an injury caused by a sharp and pointed instrument.
Dra. Ophelia T. Rivera, who performed the autopsy, noted a single lacerated wound on the victim's left chest with rib fractures, lung penetration, and partial heart perforation, indicating death was inevitable.

SPO4 Antonio Zabala and SPO4 Salvador Samson testified regarding the investigation, detailing the recovery of the weapon and the circumstances surrounding the accused’s arrest.
The arrest account included that Rey Solis was apprehended in Gapan, Nueva Ecija through the intervention of local authorities, with a noted absence of any immediate voluntary surrender.

Rey Solis admitted to having killed the victim but raised a plea of self-defense.
According to his version, an accidental bump led to the victim slapping him, after which the victim brandished a knife.
Solis claimed that during the ensuing struggle for the weapon, he ended up holding the victim by the neck and subsequently stabbing him.
He further stated that following the incident he left the scene, later seeking assistance to surrender, although the police records indicate he was arrested under a warrant.

The trial court, after evaluating the evidence and witness testimonies, found Rey Solis guilty beyond reasonable doubt of murder qualified by treachery and imposed the capital penalty of death.
It also ordered Solis to pay actual, moral, and indemnity damages to the victim’s widow, Delia Uligan, and to forfeit the weapon used in the commission of the crime.
The information charging murder was based on the alleged use of treachery and abuse of superior strength, although the accused’s version centered on self-defense.

The trial court erred in finding him guilty of murder by qualifying the crime with treachery.
The imposition of the death penalty was improper, particularly since he sought to mitigate his liability by claiming self-defense and voluntary surrender.

The accused’s self-defense claim was scrutinized in light of the fixed eyewitness testimony and the evidentiary record.

Whether the trial court erroneously found the accused guilty beyond reasonable doubt of murder qualified by treachery rather than the lesser offense of homicide.

Did the evidence sufficiently establish the presence of treachery as an aggravating circumstance?
Was the alleged abuse of superior strength correctly applied to elevate the killing to murder?

Whether the accused’s plea of self-defense satisfies all the requisite elements to exempt him from criminal liability.

Was there an actual, sudden, and unexpected attack on the victim?
Were the means employed by the accused reasonably necessary and proportional to the threat?
Did the accused provoke the victim in any manner that would void the self-defense claim?

Whether the trial court erred in not giving due weight to the claim of voluntary surrender as a mitigating circumstance.

The proper quantum of compensatory damages (actual, moral, and indemnity) to be awarded to the victim’s heirs based on the evidence presented.