G.R. No. 192150 - SABAY vs. People

On the afternoon of June 12, 2001, petitioner Federico Sabay and his daughter, Erlinda Sabay, were laying wood and water pipes on the yard of Godofredo Lopez.
Godofredo confronted the petitioner regarding the alleged intrusion into his property, resulting in a verbal altercation.
During the altercation, Erlinda hit Godofredo on the head with a hard object. The petitioner threw a stone at Godofredo’s face, breaking his eyeglasses. Godofredo claimed to have felt dizzy as a result.
Jervie Lopez intervened to pacify the parties but was hit on the hand with a bolo. Neighbors also intervened shortly after.

Medico-legal certificates dated June 12, 2001, indicated that Godofredo sustained a contusion on the left parietal area of his head and an abrasion on his left cheek; Jervie sustained a wound on his right palm.
On June 13, 2001, Godofredo and Jervie filed complaints against the petitioner before the barangay.
The parties agreed to settle based on a recommendation by the building inspector, signed in a Kasunduang Pag-aayos (Kasunduan) dated June 20, 2001.

The Kasunduan was not implemented because the building inspector failed to issue the promised recommendation to resolve the boundary dispute.
The Barangay Captain issued a Certification to File an Action indicating no settlement was reached.
The petitioner was charged before the Metropolitan Trial Court (MTC) with two counts of Slight Physical Injuries under separate Informations, and charged with Light Threats along with Erlinda.

The petitioner pleaded not guilty and claimed self-defense at trial.
The prosecution presented eyewitnesses Rodolfo Lata, Dina Perez, Godofredo, Jervie Lopez, and Dr. Melissa Palugod.
The defense presented the petitioner, Wilfredo Verdad, and Caridad Sabay.
The petitioner alleged that Godofredo attacked him with an iron bar and that Godofredo’s son fired a gun at him, prompting him to defend himself by throwing a stone.

The MTC found the petitioner guilty beyond reasonable doubt of two counts of slight physical injuries; dismissed light threats charges as absorbed in the physical injuries offense.
The MTC rejected the petitioner’s claim of self-defense due to lack of evidence, including failure to present medical records of his injury.
The Regional Trial Court (RTC) affirmed the MTC decision.
The petitioner appealed to the Court of Appeals (CA), asserting: (a) lack of jurisdiction of the MTC because the Certification to File an Action was not admitted in evidence; (b) erroneous rejection of self-defense claim.
The CA affirmed the RTC decision, admitting the certification despite lack of formal offer, and sustaining findings on self-defense.
The CA denied the motion for reconsideration; petitioner filed present petition for review on certiorari.

Whether the MTC has jurisdiction over the criminal cases in light of the alleged inadmissibility of the Certification to File an Action and failure to comply with conciliation procedures under Presidential Decree No. 1508.

Whether the lower courts erred in finding the petitioner guilty beyond reasonable doubt and in rejecting his claim of self-defense.