G.R. No. 216018 - People vs. Vega y Ramil

The accused, Don Vega y Ramil, was charged with Murder under Article 248 of the Revised Penal Code.
The incident occurred on January 18, 2009, in the City of Manila, Philippines.
The Information alleged that Don intentionally, with treachery and evident premeditation, assaulted Manuel Isip y Padilla (also known as Manuel Isip @ Antuling) using a bladed weapon, inflicting fatal stab wounds.

According to the prosecution, events transpired around 11:30 p.m. on Arellano Street, Malate, Manila during a drinking gathering.
The victim, Manuel, was present with a group of about 15 people celebrating a birthday, accompanied by friends including witness Aldrin R. Fernandez.
Don, seen sniffing rugby from a bottle, allegedly approached the group, created a disturbance by smashing objects, and exchanged harsh words with Manuel.
As Manuel turned his back to avoid escalating the conflict, Don allegedly seized him from behind and repeatedly stabbed him on various parts of his body.
The victim was rushed to the Ospital ng Maynila but was pronounced dead on arrival, with the fatal injuries attributed to four deep stab wounds on the chest.

Don’s version differed significantly; he claimed he was at Tuazon Street, San Andres, Manila, drinking with Manuel and others, including individuals named Fernandez, Ogad, Jeffrey, and the celebrant’s father.
He maintained that the atmosphere was convivial until he repeatedly requested that Manuel play his theme song during the gathering, a request which Manuel allegedly ignored.
Don claimed that an altercation ensued when Manuel punched him after he approached, prompting Don to pick up a bladed weapon, react impulsively, and stab Manuel as the latter charged at him.
He asserted that he did not intend to kill Manuel, describing the act as unintentional and regrettable, emphasizing that the victim was unarmed and that he later fled the scene before surrendering to the authorities.

The Regional Trial Court (RTC), Branch 42, Manila, convicted Don for Murder on May 31, 2011, citing all elements of Murder as present and rejecting the self-defense claim.
The RTC noted, among other points, that the sudden, unprovoked, and treacherous nature of the attack—attacked from behind with a bladed weapon—negated any claim of self-defense.
On appeal, the Court of Appeals (CA) in its Decision dated May 12, 2014, affirmed the RTC’s conviction but modified it by ordering a higher amount for damages and ultimately discussing whether the qualifying circumstance of treachery was adequately proven.

Whether the trial court and the Court of Appeals erred in convicting Don of Murder given the circumstances of the case.
Whether the accused successfully established the defenses, particularly the claim of self-defense, by proving the presence of unlawful aggression and the necessity of the means employed.

Whether the prosecution proved by clear and convincing evidence that the killing of Manuel was attended by treachery.
Whether the elements of treachery, being the sudden and deliberate nature of the attack that deprived the victim of any chance to defend himself, were satisfied.

Whether the accused met the burden of proving self-defense by establishing three requisites: unlawful aggression, reasonable necessity of the means used, and lack of sufficient provocation.
Whether the absence of corroborative evidence and the unarmed status of the victim precluded a valid self-defense argument.