Case Digest (G.R. No. 153699)
Facts:
Celerino Sanchez v. People of the Philippines, G.R. No. 161007, December 06, 2006, Supreme Court Third Division, Tinga, J., writing for the Court.Petitioner Celerino Sanchez was charged by Information dated March 24, 1994 (Criminal Case No. 94-10-430) with the killing of Felix Jamero on September 4, 1993 in Barangay San Jose, Mahayag, Zamboanga del Sur. The Information alleged that Sanchez, armed with a bolo, assaulted and inflicted multiple stab wounds upon Jamero resulting in his death.
At arraignment Sanchez pleaded not guilty and trial followed before the Regional Trial Court, Branch 23, Molave, Zamboanga del Sur. The trial court found Sanchez guilty of homicide and imposed an indeterminate penalty of eight years and one day of prision mayor as minimum to fifteen years of reclusion temporal as maximum, and ordered payment of moral, exemplary and funeral damages totaling P165,000.
Sanchez appealed to the Court of Appeals, contending he acted in self-defense and invoking mitigating circumstances (voluntary surrender, passion and obfuscation). The Court of Appeals affirmed the conviction but reduced the penalty in light of voluntary surrender, imposing six years and one day of prision mayor as minimum to twelve years and one day of reclusion temporal as maximum; all other aspects of the trial court decision were affirmed.
Sanchez filed a petition with the Supreme Court dated November 17, 2003 contesting the appellate disposition and maintaining that he acted in self-defense. The Office of the Solicitor General filed a Comment (Sept. 16, 2004) opposing the plea of self-defense; Sanchez filed a Reply (Nov. 11, 2004). Key trial testimony from eyewitness Saturnino Umambac described the sequence: Jamero raised a shovel as if to strike Sanchez, the shovel became stuck in mud, Jamero threw mud and then ran into a water-filled rice field; Sanchez allegedly pursued, caught up with Jamero, hacked and stabbed him repeatedly, rode on him and pushed his face into the mud; later Sanchez’s son-in-law t...(Subscriber-Only)
Issues:
- Did petitioner satisfactorily prove the plea of self-defense (i.e., was there unlawful aggression by the victim, reasonable necessity of the means employed, and lack of sufficient provocation)?
- Can incomplete self-defense excuse or mitigate criminal liability under the facts, given whether unlawfu...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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