G.R. No. 141961 - Sta. Clara Homeowners' Association vs. Spouses Gaston

On or about September 16, 1997, at approximately 9:00 o’clock in the evening, Alexander P. Rugas was charged with frustrated homicide for allegedly attacking and stabbing Herberto Rafol in Barangay Taclobo, San Fernando, Romblon.
The Information recites that the accused, with intent to kill, willfully and unlawfully attacked the victim with a deadly weapon, inflicting critical wounds that ordinarily would have resulted in death had timely medical intervention not prevented it.

The prosecution established that at the time of the incident, Rafol was seen conversing with Perla Perez near the residence of Anda Romano when the accused suddenly appeared approximately twenty-five (25) meters away and attacked him.
According to medical evidence compiled by Dr. Fermin M. Fatalla, Rafol sustained two stab wounds:

A fatal wound in his right upper abdominal quadrant, which penetrated the abdominal cavity and the right lobe of the liver, risking severe hemorrhage.
A non-fatal wound on the uppermost part of the left lateral thigh.

Witnesses, including private complainants and neighbors, testified regarding the events—from seeing the accused running with a knife to witnessing the aftermath of the stabbing—and produced supporting exhibits such as medico-legal certificates, sketches, and various photographs.
Evidence also revealed that the victim’s incurred injuries necessitated medical treatment and led to expenses amounting to P25,390.00.

The petitioner contended that prior to the altercation he was in his aunt’s house, slicing lemon, when he heard shouting outside, prompting him to investigate the commotion.
Upon emerging, he encountered a group consisting of Crispulo Romano, Joval Rones, and Herberto Rafol.
The petitioner asserted that:

Rafol was armed with a bolo and had already physically assaulted him by kicking his left arm.
Outnumbered and pressured by adversaries, he resorted to using his knife in self-defense.
The ensuing encounter involved a fistfight which escalated when he stabbed Rafol—first on the side (as corroborated by the sketch and testimonies) and then again after retrieving his knife.

The precise location of the stabbing (initially described as “in front” versus evidence indicating otherwise).
Details about the physical injuries he allegedly sustained (e.g., claiming an injury to his left arm but later mentioning no injury to his eyebrow).

The Regional Trial Court found the petitioner guilty beyond reasonable doubt of frustrated homicide.
The trial court highlighted:

Inconsistencies in the petitioner’s testimony and contradicting statements regarding his injuries and the manner of the stabbing.
The failure to prove a bona fide self-defense claim, evidenced by the absence of any police report or surrender to authorities and the unaccounted-for knife.
That the petitioner’s voluntary engagement in the fight, without clear provocation, negated his claim to self-defense.

The petitioner's case was further weakened by the generic aggravating circumstance of treachery as observed by the trial court.

On appeal, the Court of Appeals affirmed the trial court’s decision with modifications.
The appellate court reiterated that:

The petitioner failed to meet the burden of proving self-defense, given the lack of evidence regarding an imminent threat.
The inconsistency in his account—especially concerning the location of his injuries and his handling of the weapon—undermined his argument.
The prosecution witnesses’ testimonies were found credible and consistent, leading to the reaffirmation of the petitioner’s guilt.

The court modified the decision by imposing additional damages against the petitioner.

Whether the accused proved, with clear and convincing evidence, that his actions were in complete self-defense.
Whether he established the essential requisites, such as the presence of unlawful aggression, necessity of the means, and absence of sufficient provocation.

Whether the inconsistencies and contradictions in the petitioner’s testimony versus the prosecution’s witnesses warranted rejection of his version.
Whether the trial court correctly assessed the credibility of the witnesses who testified to the events.

Whether the finding of the aggravating circumstance of treachery was applicable given that it was not expressly alleged in the Information.
Whether the imposition of such aggravating circumstances, albeit generic, was justified under the factual matrix of the case.

The issue of the petitioner’s failure to account for the knife used in the commission of the crime.
The procedural improprieties related to his failure to surrender or document his claim of self-defense to the appropriate authorities.