Title
Floro Galorio y Gapas vs. People
Case
G.R. No. 254531
Decision Date
Feb 19, 2024
Petitioner stabbed Andres Muring during a fiesta altercation, claiming self-defense. Court ruled against him, affirming Homicide conviction due to unproven self-defense and lack of unlawful aggression.

Case Summary (G.R. No. 254531)

Information and Prosecutorial Finding (Probable Cause)

The Information filed September 4, 2006 charged petitioner with homicide for stabbing and causing the death of Andres Muring on or about May 24, 2006, at Alicia, Bohol. The Office of the Provincial Prosecutor of Bohol conducted a preliminary investigation and issued a Resolution finding sufficient evidence to engender a well-founded belief that petitioner probably committed homicide, recommending filing of the Information. The OPP’s factual summary indicated an altercation during a coronation night program, that Andres arrived with a bolo and allegedly initiated a violent attack resulting in multiple injuries to petitioner and his nephews, and that petitioner stabbed Andres causing a fatal injury.

Documentary and Affidavit Evidence Submitted to the Prosecutor

Attached to the OPP Resolution were: the victim’s Certificate of Death (fatal stab wound penetrating the liver causing hypovolemic shock); the Alicia Police Station initial report describing the sequence of a market confrontation and mutual stabbing/hacking; multiple affidavits (two prosecution eyewitness affidavits by Leoncio and Antonio, petitioner’s counter-affidavit, and several counter-affidavits by petitioner’s relatives and neighbors); medico-legal and confinement certificates describing wounds to petitioner, Eric, and Rother; and certification of petitioner’s membership in a civilian volunteers’ organization.

Core Factual Contest and Witness Accounts at Trial

The primary factual dispute concerned who was the initial and continuing aggressor and whether petitioner acted in defense of himself or of his nephew. Prosecution eyewitnesses (Leoncio and Antonio) in affidavits described petitioner stabbing Andres while Andres was on the ground. Leoncio’s trial testimony contradicted parts of his affidavit: he testified he did not notice the victim wielding a bolo and later admitted familial relation to the victim’s widow and that an affidavit attributed to him had been prepared by the widow’s counsel without adequate explanation. Petitioner and several defense witnesses testified that Andres arrived, threatened petitioner, immediately attacked with a long bolo, inflicted multiple wounds on petitioner and his nephews, and that petitioner, after being wounded and retreating, retrieved a bayonet/knife from his motorcycle and stabbed Andres while Andres was attacking petitioner’s nephew Eric. Other witnesses (Benedicto, Eddie Mar, Rother) corroborated that Andres was the initial attacker and that petitioner and his relatives sustained multiple attacks and injuries. There were inconsistencies in details (e.g., exact direction of stab, exact wound locations), witness biases (family relationships), and differences between some affidavit statements and in-court testimony.

RTC Decision and Findings

RTC Branch 51 convicted petitioner of homicide in a decision promulgated July 28 (noted by the record as July 29), 2015, sentencing him to prision mayor to reclusion temporal and awarding moral damages. The trial court credited the testimony of prosecution witness Leoncio and found the defense theory of self-defense/defense of a relative unconvincing. The RTC emphasized the absence of concrete details about the alleged attack on Eric and concluded petitioner and his relatives were likely armed and prepared; it regarded petitioner’s account of retrieving a bayonet from his motorcycle while grievously wounded as incredible. The RTC nevertheless recognized a mitigating circumstance (lack of intent to commit so grave a wrong) and reduced the penalty accordingly.

Court of Appeals Ruling

The Court of Appeals (20th Division) denied petitioner’s appeal, affirmed the RTC decision with modifications, and increased monetary awards to the heirs (civil indemnity and moral damages of PHP 50,000 each, with interest) applying People v. Jugueta for quantum. The CA held that the prosecution proved the elements of homicide, that the victim’s death was proven, and that the justifying circumstances of self-defense or defense of a relative were not established because, in the CA’s view, the victim’s unlawful aggression had ceased when Eric pointed a gun and the victim fell; the CA treated petitioner’s return to retrieve the bayonet as retaliation rather than a justified defensive act. The CA denied petitioner’s motion for reconsideration.

Issues Brought to the Supreme Court

The petition presented three core issues: (1) whether the petition raised pure questions of law cognizable by the Supreme Court under the certiorari remedy, in light of exceptions permitting review of factual findings; (2) whether petitioner’s constitutional right to speedy trial under the 1987 Constitution and RA No. 8493 was violated; and (3) whether the factual findings and conclusions below should be reversed such that petitioner would be acquitted.

Justiciability and Exceptions to the Rule on Factual Findings

The Court recalled established exceptions allowing reexamination of factual findings on certiorari (as in Fuentes and related authorities) where findings are contradictory, speculative, manifestly mistaken, or where courts overlooked material evidence. The Court concluded that exceptional circumstances existed here—trial court errors and appellate perfunctoriness warranted re-calibration of factual findings rather than applying the general rule of deference.

Speedy Trial Analysis and Timeline of Delays

The Court examined RA No. 8493 and relevant jurisprudential factors (length and reasons for delay, assertion of the right, prejudice) and summarized the procedural timeline from the Information (2006) through arraignment (January 8, 2007) and trial events (pre-trial reschedulings, late or cancelled hearings, unknown or unexplained gaps, the last hearing in May 2014, and decision in 2015). The Court found multiple, often unexplained, and oppressive delays: arraignment nearly three months post-arrest; protracted postponements of pre-trial primarily for private complainant nonappearance despite law not requiring private complainant presence; repeated court cancellations with no reasons; unexplained lapses of over a year in trial continuity; and trial court’s failure to resolve petitioner’s Motion to Dismiss on speedy trial grounds. The Court applied the Speedy Trial Act’s timelines and exclusions, noting the accused’s failure to raise the issue on appeal but recognizing exceptions where counsel’s omission would produce an outright deprivation of liberty or where interests of justice require intervention. On balance the Court found that the right to speedy trial had been violated and that dismissal of the charge on that ground was warranted; the Court nonetheless proceeded to address the merits and concluded acquittal was proper on the substantive justification ground.

Legal Standard for Defense of a Relative and Evidentiary Burden

The Court restated that when an accused admits the killing but invokes a justifying circumstance (self-defense or defense of a relative), the accused bears the burden to establish that justification by clear and convincing evidence. Article 11, paragraph 2, RPC requires (1) unlawful aggression; (2) reasonable necessity of the means employed to repel the aggression; and (3) absence of participation in the provocation by the person making the defense (if provocation existed). The Court emphasized the proper standard: evaluate the accused’s belief and reasonableness from his standpoint at the time of action, not b

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