G.R. No. 137296 - People vs. Vicente y Quinto

The incident occurred on or about May 30, 1998, at Barangay Gueguesangen, Mangaldan, Pangasinan.
The appellant, Dionisio Q. Vicente, was charged in the Information for the crime of murder, which occurred during an altercation involving family members and the victim, Manuel C. Quinto, Jr., wherein a stabbing led to the latter’s death.
The trial court (Branch 42, Dagupan City) initially found appellant guilty beyond reasonable doubt of murder and sentenced him to reclusion perpetua with corresponding civil indemnities, actual damages, attorney’s fees, moral damages, and other expenses.

A family squabble occurred between appellant’s brothers-in-law, Anoy and Sonny.
The victim, then serving as Chairman of the Sangguniang Kabataan, intervened after being provoked by unusual shouting.
The victim pushed Anoy, and appellant attempted to pacify him by dismissing the incident as mere family quarrel.
Feeling insulted by the appellant’s remark, the victim left to get a steel pipe and later hit the appellant on his upper left arm.
This friction established an initial physical altercation where the victim displayed aggression toward the appellant.

After the initial incident, while appellant was conversing with Kagawad Elias Fernandez outside his house, the victim reappeared.
The victim, in a seemingly reconciliatory mood, tapped the appellant’s right shoulder and invited Kagawad Fernandez to the dance hall while extending a handshake.
The appellant, still agitated from the previous conflict, drew a knife and, during a struggle for control of the weapon, accidentally stabbed the victim in the chest.
The sequence culminated with the victim’s declaration, “Pare, I was hit,” and subsequent transport to the hospital where he was pronounced dead on arrival.
Appellant immediately surrendered himself to Kagawad Fernandez, who brought him to the police, and was later brought for medico legal examination.

Witnesses Hilda Vicente, Linda Vicente, and Dr. Ophelia Rivera testified for the defense.
According to the defense, the altercation began as a result of familial discord, and the victim’s initial aggressive act (hitting the appellant with the steel pipe) warranted a reaction born out of anger rather than a premeditated or retaliatory killing.
The defense stressed that the appellant’s subsequent injury also evidenced a self-defense claim.

Prosecution witnesses (Jose Noe, Sr., Ronald Terte, and Juliana Quinto) provided a detailed account that contradicted the defense’s version.
Their testimonies established that:

The victim was not in an aggressive stance when he approached the appellant in the second stage.
It was the appellant who drew his own knife and instigated the fatal thrust in the chest of the victim.
The victim’s earlier aggressive act had ceased, thus negating the justification for self-defense.

The physical evidence included the location of the stab wound (in the chest) and the fact that the weapon used was the appellant’s “rambo knife,” which was not surrendered to the authorities.

Dr. Ophelia Rivera testified regarding the appellant’s physical injuries (hematoma on the upper left arm and head pain) and the medical cause of death (“cardiorespiratory arrest secondary to hypovolemic shock due to a stab wound”).
The trial court’s decision emphasized that treachery was present, characterizing the appellant’s act as a deliberate and unexpected thrust during a moment when the victim was unprepared and in a conciliatory mode.
The mitigating circumstance of voluntary surrender was noted, as appellant promptly turned himself over to a person in authority (Kagawad Fernandez).

The trial court erred by giving undue credence to the appellant’s claim of self-defense.
The trial court erroneously found the qualifying circumstance of treachery.
The trial court should have convicted him only of homicide instead of murder.

The Solicitor General countered, arguing against the self-defense claim and supporting the presence of treachery based on the element of surprise and the victim’s lack of an ongoing aggressive posture.

Whether the trial court erred in accepting the appellant’s claim of self-defense despite the evidence suggesting that unlawful aggression had ceased during the second stage of the incident.
Whether the trial court correctly found the presence of treachery as a qualifying aggravating circumstance during the commission of the crime.
Whether the appellant’s actions, taken during two distinct stages of the altercation, justify a conviction for murder (with treachery) as opposed to homicide, given that the victim was unarmed and in a reconciliatory posture during the fatal encounter.
Whether the mitigating circumstance of voluntary surrender was sufficiently considered in imposing the sentence and corresponding penalties.