G.R. No. 160341 - Senoja vs. People

On April 16, 1997, Exequiel Senoja, Fidel Senoja, Jose Calica, and Miguel Lumasac were drinking gin at the hut of Crisanto Reguyal in Barangay Zarah, San Luis, Aurora.
Leon Lumasac, armed with a bolo and in search of his brother Miguel, suddenly arrived; his agitation was evident as he hacked at the doorpost and displayed aggressive behavior.
Initially, Exequiel Senoja and Jose Calica attempted to pacify Leon, with the petitioner personally approaching Leon and trying to calm the situation.
In the process, the petitioner embraced Leon to thwart his attempted hack while Jose Calica seized the bolo and Fidel Senoja took possession of the petitioner’s knife.
Following these actions and an exchange of words, a temporary reconciliation occurred between Leon and the petitioner within the hut.

After the initial reconciliation inside the hut, Leon exited the premises, followed by Exequiel Senoja.
Approximately ten meters away from the hut, the situation escalated when Leon turned around and confronted the petitioner.
In a sudden turn, the petitioner stabbed Leon; initially piercing the left buttock and when Leon turned, he continued stabbing him repeatedly, inflicting several fatal wounds.
A medico-legal examination conducted by Dr. Pura Deveza Valenzuela-Uy revealed multiple lesions, including five fatal stab wounds on the chest, along with other non-fatal wounds on the buttock and defensive injuries on the left palm.
The physical evidence was corroborated by other testimony (e.g., Dr. Rodolfo Eligio) regarding the positions and nature of the wounds, indicating a series of aggressive stabbings by the petitioner after Leon had ceased initiating an attack.

An Information was filed on August 13, 1997, charging Exequiel Senoja with homicide, specifying that his actions were willful, unlawful, and executed with intent to kill by means of multiple stabbings with a bladed weapon.
The petitioner admitted to killing Leon Lumasac but presented an affirmative defense of self-defense, contending that he was reacting to an initial attack by Leon.
The Regional Trial Court found the petitioner guilty beyond reasonable doubt of homicide and sentenced him to a prison term along with civil indemnity to the victim’s heirs and the payment of costs.
The petitioner subsequently appealed, asserting that critical facts—particularly regarding the sequence and physical plausibility of the injuries—was erroneously evaluated, which if properly considered, would have supported his plea of self-defense.

The Court of Appeals, while modifying certain findings, affirmed the trial court’s judgment, highlighting inconsistencies in the petitioner’s narrative versus the physical evidence.
Emphasis was placed on the contrast between the petitioner’s version (alleging a sudden, defensive attack by Leon) and the forensic report showing multiple stab wounds predominantly inflicted after Leon was no longer the aggressor.
Critical observations included:

The improbability of Leon, while being attacked, generating nine fatal wounds against an assailant.
The discrepancy in the locations of wounds and the sequence of switching weapons, which undermined the self-defense claim.
The petitioner’s failure to surrender his knife and his inconsistent testimony regarding the site and nature of the wounds.

The appellate court noted that physical evidence, being the highest form of evidence, clearly contradicted the petitioner’s account of events.

Whether the petitioner’s act of stabbing Leon Lumasac was legally justifiable under the doctrine of self-defense.

Analysis of whether an initial aggressive act by Leon Lumasac transformed into a situation where self-defense was no longer tenable.
Determination if the petitioner’s subsequent pursuit and repeated stabbing of the victim, after the initial altercation, exceeded the limits of necessary defensive action.

The credibility and consistency of the petitioner’s testimony versus the physical evidence.

Examination of the discrepancies between the petitioner’s statement regarding the events (e.g., location of the stabbing, number and nature of wounds) and the forensic findings.
Evaluation of the corroborative testimonies and the factual findings of both the trial court and the Court of Appeals.

Whether the sequence of events and the evidentiary record support the conviction for homicide rather than a justified claim of self-defense.

Scrutiny if factors such as the petitioner’s decision to follow Leon after reconciliation and his subsequent aggressive actions constituted an unlawful aggression rather than a defensive act.

The proper interpretation of the requirements for self-defense: the presence of an actual, immediate threat, the proportionality of the response, and the cessation of the aggressor’s hostile actions.