Facts:

In the case of The People of the Philippines vs. Danilo Valencia and Reynaldo Valencia, the defendants, father and son, were found guilty of murder by the Circuit Criminal Court of San Fernando, Pampanga, in Criminal Case No. CCC-V-1657. The incident occurred on May 14, 1978, at approximately 4:00 PM, when Reynaldo Valencia and his son Danilo went to the residence of Armando Salazar in Bernales Compound, Bayan, Orani, Bataan. Reynaldo was armed with two large stones, while Danilo carried a long bolo. Upon arrival, Reynaldo shouted a challenge to Salazar, prompting him to come out of his house. When Salazar emerged, Reynaldo threw a stone at him, which he dodged. Reynaldo then physically restrained Salazar, allowing Danilo to strike Salazar multiple times with a bamboo staff before hacking him with the bolo. Salazar fell to the ground, but Danilo continued to inflict injuries on him. After the assault, Salazar was taken to the Orani Emergency Hospital and later transferred t...

Facts:

Incident Overview

• On May 14, 1978, around 4:00 PM, Reynaldo Valencia and his son Danilo Valencia went to the house of Armando Salazar in Bernales Compound, Bayan, Orani, Bataan.
• Reynaldo carried two big stones, while Danilo was armed with a long bolo.
• Upon arrival, Reynaldo shouted, "Putang ina mo Manding, kung tunay kang Lalake, lumabas ka," challenging Salazar to come out.

Attack on Armando Salazar

• Salazar came out of his house, and Reynaldo threw a stone at him, which Salazar dodged.
• Reynaldo then rushed at Salazar, held his hands behind his back, and Danilo struck Salazar multiple times with a bamboo staff and hacked him with a bolo.
• Salazar fell to the ground, but Danilo continued to attack him, hitting him on the head and body.
• The Valencias left the scene afterward.

Medical and Legal Proceedings

• Salazar was taken to Orani Emergency Hospital and later transferred to the Philippine General Hospital in Manila, where he died after 16 days.
• Dr. Prospero A. Cabayanan, a Senior Medical Officer of the National Bureau of Investigation, conducted an autopsy and determined the cause of death as "hemorrhage, meningeal traumatic."
• Policeman Gregorio David arrived at the scene, and the Valencias voluntarily surrendered the bolo used in the attack.

Defense's Version

• Reynaldo claimed he acted in self-defense, stating that Salazar stabbed him first, and he only hacked Salazar after being attacked.
• Danilo denied involvement, claiming he arrived after Salazar was already on the ground.
• The defense argued that Reynaldo's wounds were self-inflicted or inflicted by others to justify self-defense.

Issue:

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Ruling:

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Ratio:

1. Self-Defense: The burden of proving self-defense lies with the accused. Reynaldo failed to provide clear and convincing evidence to support his claim. His actions, including provoking the victim and initiating the attack, negated the claim of self-defense.
2. Conspiracy: The Court found that both Reynaldo and Danilo acted in concert, as they arrived together armed with weapons and jointly attacked Salazar. However, the crime was classified as homicide, not murder, due to the absence of treachery.
3. Treachery: Treachery requires that the attack be sudden and unexpected, giving the victim no opportunity to defend themselves. In this case, Salazar was aware of the impending attack after being challenged, so treachery was not present.
4. Credibility of Witnesses: The testimonies of prosecution witnesses, including Salazar's wife and brother, were deemed credible and consistent, while the defense's version was found implausible.