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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Case Background and Nature of the Appeal
- The appellant, David Maningding, was convicted of murder by the Regional Trial Court (RTC), Branch 44 in Dagupan City, in Criminal Case No. 2006-0688-D.
- The case was appealed to the Court of Appeals (CA), which affirmed the conviction in CA-G.R. CR-H.C. No. 03854.
- The appeal to the Supreme Court challenges the RTC’s and CA’s findings, contending self-defense as justification for the killing.
Criminal Information and Trial Proceedings
- On September 13, 2006, around 10:25 PM, in Barangay Anolid, Mangaldan, Pangasinan, Maningding stabbed Marlon Muyalde with intent to kill, inflicting a fatal stab wound characterized by treachery.
- Maningding was arraigned on December 11, 2006, and pleaded not guilty.
- A mandatory pre-trial conference was conducted before the trial.
- The prosecution presented four witnesses: Aladino Jorge (eyewitness and sari-sari store owner), Dr. Virgilio De Guzman (medical examiner), Rommel Muyalde (victim's brother), and Gloria Muyalde (victim’s wife).
- The defense presented only the accused as its witness.
Prosecution’s Version of Facts
- Aladino Jorge witnessed the victim and his brother conversing outside his store when accused arrived.
- The victim greeted accused who remained silent, then the accused suddenly raised the victim’s hand and stabbed him under the armpit without any provocation.
- The victim shouted in pain, neighbors came out, and the accused fled.
- Dr. De Guzman testified on the fatal nature of the wound: a 14-inch deep stab at the right intercostal space causing massive liver laceration and hypovolemic shock leading to death.
- Rommel Muyalde corroborated the stabbing incident and the accused’s flight, affirming no exchange of words before the attack.
- Gloria Muyalde testified on the victim’s livelihood as a farmer and bottle vendor, their four children, incurred expenses (PhP 33,180), and established civil liability.
Defense’s Version of Facts
- The accused claimed he was returning from work and saw the victim and others drinking.
- The victim supposedly invited him to drink and embraced him, during which the accused noticed the victim pulling a knife.
- The accused testified that he grabbed the knife but was unaware he had stabbed the v