Title
People vs. David Maningding
Case
G.R. No. 195665
Decision Date
Sep 14, 2011
David Maningding was convicted of murder for fatally stabbing Marlon Muyalde without provocation, leading to affirmed appeal and sentencing to reclusion perpetua.

Case Summary (G.R. No. 195665)

Facts of the Case

The accusation against David Maningding arose from an Information dated November 7, 2006, detailing that he, armed with a bladed weapon, attacked Marlon Muyalde with intent to kill, resulting in Marlon's death. Following his arraignment on December 11, 2006, where he pleaded not guilty, a trial commenced. The prosecution presented testimonies from various witnesses including Aladino, Dr. De Guzman, Rommel, and Gloria, while the defense relied solely on the testimony of the accused.

Prosecution's Version of Facts

The prosecution's first witness, Aladino, testified about the circumstances leading to the stabbing incident, highlighting that he saw accused Maningding arrive and stab Marlon without any provocation while they were conversing. Aladino affirmed that he was close to the scene and later identified Maningding in court. Dr. De Guzman confirmed that Marlon had a fatal stab wound that led to his death, establishing the extent of injuries sustained during the attack. Rommel, the victim's brother, corroborated Aladino's account, stating the accused made a sudden attack after being greeted by Marlon. Gloria, the victim's wife, testified about the deceased's contributions to their family and detailed the financial repercussions of his death.

Defense's Version of Facts

In contrast, accused Maningding claimed he acted in self-defense. He testified that he was approached by the victim who invited him for drinks and that during this encounter, Marlon allegedly pulled out a knife. Maningding asserted that he did not intend to stab Marlon, emphasizing that he was surprised when the stabbing occurred. No other effective evidence or witnesses were presented by the defense to support this claim.

Ruling of the Trial Court

The Regional Trial Court (RTC) found Maningding guilty of murder, concluding that the prosecution's eyewitnesses were credible and that the evidence weighed against the defense. The RTC established that there was treachery involved, as the assault was sudden and without warning to the victim. Consequently, Maningding was sentenced to reclusion perpetua and ordered to pay various damages to the victim's heirs.

Ruling of the Appellate Court

Maningding appealed the RTC's decision, reiterating his claim of self-defense. However, the Court of Appeals affirmed the RTC's ruling, emphasizing that the essential element of unlawful aggression was absent, thereby upholding the conviction based on the established treachery and the lack of support for his self-defense claim.

Issues Raised

The primary issue on appeal was whether the RTC erred in its conviction of the accused, particularly regarding his assertion of self-defense.

Court's Ruling

The higher court maintained the RTC's conviction, supporting the factual determinations made by the trial court. It reiterated that an accused invoking self-defense bears the burden to demonstrate its elements, namely unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. In this instance, it was concluded that Maningding failed to establish any of these necessary elements, as the victim had not exhibited any aggression prior to the attack.

Conclusion on Treachery

The court affirmed that treachery was evident, evidenced by the sudden and unexpected nature of the attack. The testimonies presented confirmed that Marlon had no o

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