G.R. No. 158053 - Razon y Lucea vs. People

On the night of August 1, 1993, Francisco Chopchopen was walking toward Upper Pinget, Baguio City when a taxicab driven by Edwin Razon y Lucea stopped beside him.
Razon explained that he had been held up by three men at Dreamland Subdivision.
Chopchopen persuaded Razon to accompany him to the alleged incident site, located approximately 100 meters up the road.

While about eight meters off the road, Chopchopen observed an individual lying on the ground, partially concealed by a large stone.
Closer observation revealed the victim’s shirt drenched in blood and labored breathing; a wooden cane was found nearby.
The victim was later identified as Benedict Kent Gonzalo, a 23-year-old polio victim.
Chopchopen requested Razon to help transport the injured man to Baguio General Hospital.

During transport, when questioned by Chopchopen if he was responsible for the stabbing, Razon denied the allegation initially.
Upon the appearance of a police mobile patrol driven by SPO2 Samuel Bumangil, Razon explained that he had been held up by three men, one of whom was Gonzalo, and claimed that he had stabbed Gonzalo in self-defense.
Razon produced a fan knife as the purported weapon; however, a subsequent search revealed another knife—a colonial knife marked with bloodstains under a newspaper near the steering wheel.
At the police station, Razon admitted to stabbing Gonzalo yet maintained that his action was taken in self-defense.

A 2.5 cm stab wound on the front and lower quadrant of the abdomen, penetrating vital organs and measuring an approximate depth of 12 cm, which was fatal.
A 5 cm wound on the left arm with mixed blunt and sharp ends, about 1 cm in depth.
A 1.3 cm wound on the right buttock, approximately 4 cm deep.

Additional abrasions and contusions were noted on various parts of the victim’s body, supporting the violent nature of the encounter.

The Regional Trial Court (RTC), after considering the testimonies and evidence, convicted Razon of homicide.
The RTC sentenced Razon to an indeterminate penalty ranging from 6 years and 1 day of prision mayor as minimum to 14 years 8 months and 1 day of reclusion temporal as maximum.
Razon was also ordered to pay:

Razon filed a notice of appeal and was subsequently required by the Court of Appeals (CA) to submit an appellant’s brief.
His counsel, Atty. Rigoberto D. Gallardo, filed motions for extension of time but later moved to withdraw as counsel, filing a motion on January 7, 1999, alleging Razon’s disinterest in the proceedings.
Due to conflicting manifests regarding the withdrawal (one motion purportedly bearing Razon’s signature and another stating inability to secure his signature), the CA directed Razon to authenticate the signature and secure new counsel within a specified period.
Despite multiple resolutions and notices—ranging from orders to manifest the authenticity of the signature, file an appeal brief, or appoint counsel de oficio—Razon failed to comply punctually.
Ultimately, on January 31, 2001, the CA dismissed Razon’s appeal on the ground that it had been deemed abandoned in light of his non-compliance with procedural directives.
Razon later filed a motion for reconsideration, arguing that he could not understand the CA’s communications due to his educational deficiency and alleging negligence by his former counsel. The CA, however, denied this motion as untimely and unsupported by the circumstances.

Razon further contended that he acted in self-defense when he stabbed Gonzalo.
According to his version, three men had boarded his taxi and requested a ride; during the trip, after arriving at Dreamland Subdivision, Gonzalo allegedly initiated a hold-up and threatened him with a knife.
Razon claimed that in the ensuing struggle—including a moment where he wrested the weapon from Gonzalo—he resorted to lethal force when Gonzalo attacked him, thus justifying his actions as self-defense.
Testimonies and physical evidence from the scene, however, indicated that after an initial show of aggression, Gonzalo and his companions fled, and Razon pursued and attacked Gonzalo with both the recovered and an additional knife, shifting the dynamics from self-defense to aggression.

Whether the Court of Appeals erred in dismissing Razon’s appeal for failing to timely file the required appellant’s brief, despite the claims of negligence on the part of his former counsel.
Whether Razon’s educational deficiency or the conduct of his counsel should excuse his failure to comply with the CA’s directives.

Whether Razon’s actions in stabbing Gonzalo can be legitimately justified under the doctrine of self-defense.
Whether the elements of self-defense were present, namely the existence of unlawful aggression, necessity in the means employed, and the absence of sufficient provocation.