Case Summary (G.R. No. 268355)
Facts of the Case
Domingo was accused of stabbing John with a balisong, resulting in fatal injuries to the neck and upper back. Testimonies revealed that the victim was attacked unexpectedly while in a vulnerable position, leading to his demise shortly after being transported to the hospital.
Procedural History
Upon arraignment, Domingo pleaded not guilty. The trial included testimonies from witnesses such as Sheila Caitan, who observed the stabbing, and E-Are Perez, the security guard, both corroborating the prosecution's narrative that Domingo acted with treachery. The Regional Trial Court (RTC) convicted Domingo of murder, emphasizing the nature of the attack and dismissing his self-defense claim as unconvincing.
Legal Findings and Arguments
Domingo's appeal claimed reliance on self-defense, arguing the trial court erred in assessing witness testimonies and the presence of treachery. The Court of Appeals affirmed the conviction, outlining that Domingo failed to substantiate his claim of self-defense effectively and that the prosecution's evidence demonstrated treachery in the attack.
Supreme Court's Rationale
The Supreme Court reiterated that credibility assessments are primarily within the purview of trial courts, which have the advantage of observing witness demeanor. The detailed and consistent testimonies of Sheila and E-Are were upheld, and Domingo's claims were found lacking in credible support. The Court emphasized that self-defense requires proof of unlawful aggression, and Domingo's intoxicated state at the time of the incident hampered his reliability.
Self-Defense and Treachery
The Court established that Domingo did not adequately prove the elements of self-defense, particularly unlawful aggression by the victim. The claim was further undermined by the nature of the stab wounds, which suggested intent to kill rather than mere defense. The ruling underscored that treachery was present due to the sudden and unexpected nature of the attack, which left the victim without an opportunity to defend himself.
Verdict and Sentencing
Ultimately, the Supreme Court modified the lower court's decision, finding Domingo guilty of homicide instead of murder. The elements of evident premeditation and treachery were not sufficiently established, shifting the nature of the charge. Consequently
...continue readingCase Syllabus (G.R. No. 268355)
Case Background and Charge
- Accused-appellant Domingo Banguilan y Gulan was charged with murder under Article 248 of the Revised Penal Code (RPC).
- The incident occurred on December 29, 2017, in Caloocan City, Metro Manila.
- Domingo was accused of stabbing John Paloma y Fuentes with a "balisong" bladed weapon, inflicting mortal wounds on the neck and upper back.
- The killing was allegedly characterized by treachery and evident premeditation.
- Domingo pleaded not guilty and the trial ensued.
Prosecution Evidence
- Sheila Caitan, John's coworker, witnessed the stabbing after hearing John shout while sitting and leaning on his manukan.
- Sheila saw Domingo stab John in his left neck; she screamed and called for help.
- John's wife, Analyn Paloma, found John covered in blood and brought him to the hospital where he was pronounced dead.
- Security guard E-Are Perez corroborated Sheila's testimony; he chased Domingo after the stabbing, subdued him when Domingo threatened him with the balisong.
- Police Chief Inspector Caryl Escaro conducted the autopsy confirming two fatal stab wounds on John: one on the left neck, another on left upper back.
Defense Testimony
- Domingo admitted stabbing John but invoked self-defense.
- He claimed John attempted to steal a rooster and became aggressive, trying to hit him with a metal rod.
- Domingo stated he stabbed John fearing for his life while he was drinking with his nephew near the vacant lot.
Trial Court Findings
- The Regional Trial Court found Domingo guilty of murder on December 9, 2020.
- Treachery was established due to the swift, deliberate, and unexpected nature of the attack.
- Testimonies of Sheila and E-Are were found credible and consistent.
- Domingo's self-defense claim was disregarded due to his intoxication and lack of clear perception.
- The court did not address the evident premeditation allegation.
- Domingo was sentenced to reclusion perpetua and ordered to pay civil indemnity, moral, exemplary, and temperate damages totaling PHP 275,000.
Court of Appeals Decision
- The Court of Appeals affirmed the conviction on November 15, 2022.
- Holding clarified that Domingo, raising self-defense, bore the burden to prove all elements with clear and convincing evidence, which he failed.
- No evidence corroborated Domingo's claim that John was armed or posed imminent danger.
- The locations of the wounds negated the possibility