Case Summary (G.R. No. 217974)
Key Dates
• Incident: March 19, 2010
• RTC Decision: April 17, 2012
• CA Decision: October 29, 2014
• SC Decision: March 5, 2018
Applicable Law
• 1987 Philippine Constitution
• Revised Penal Code (RPC)
– Art. 248 (Murder)
– Art. 249 (Homicide)
– Art. 11 (Justifying Circumstances: Self-Defense)
– Art. 63(2) (Indivisible Penalties)
Facts of the Case
On the evening of March 19, 2010, Lucio Silava and his wife Victoria were in their store in Hamtic, Antique. Appellant Rezor and his brother Resurreccion arrived, requesting to buy cigarettes. Victoria admitted them inside; both men then entered the kitchen where Lucio was dining. Victoria heard Lucio plead, “What wrong have I committed?” and saw both brothers stabbing him. Lucio ran outside within the fenced premises, but the assailants continued to stab him. He sustained fifteen stab wounds, four of which were fatal, and died of hypovolemic shock.
Razor fled to his brother Reno’s house in San Jose and surrendered to police the next day. The prosecution introduced Victoria’s eyewitness testimony, autopsy findings (Dr. Pacificador), crime‐scene photographs (Atty. Sy), and funeral expense receipts. Appellant testified that he acted in self-defense after Lucio allegedly threw stones, struck his knee, and attempted to stab him; he claimed he “blacked out” and later stabbed Lucio.
RTC Findings and Ruling
The Regional Trial Court found the appellant’s self-defense claim unconvincing. It credited Victoria’s positive, consistent, and detailed testimony, supported by blood-splatter photographs and autopsy results. The court held that:
- No unlawful aggression by Lucio justified appellant’s actions.
- The number, location, and severity of wounds negated a defensive purpose and demonstrated intent to kill.
- Treachery and abuse of superior strength attended the killing.
- Voluntary surrender was not established, as appellant fled and only surrendered after police were alerted by his brother.
Convicted beyond reasonable doubt of Murder under RPC Art. 248, appellant was sentenced to reclusion perpetua, ordered to pay P75,000 civil indemnity, P15,000 actual expenses, P25,000 moral damages, and costs.
CA Ruling
The Court of Appeals affirmed the RTC decision in toto. It agreed that:
• Victoria’s testimony was credible and uncontradicted in material points.
• All elements of Murder—including treachery and abuse of superior strength—were established.
• Appellant failed to prove self-defense or voluntary surrender.
Issues on Appeal
I. Credibility given to Victoria Silava’s testimony despite alleged inconsistencies.
II. Non-appreciation of incomplete self-defense as mitigating.
III. Erroneous finding of abuse of superior strength.
IV. Failure to recognize appellant’s voluntary surrender.
Supreme Court’s Analysis and Ruling
Credibility Findings: RTC’s firsthand witness assessments enjoy high respect when affirmed by the CA and unchallenged by material overlooked facts. Victoria’s clear, detailed account, supported by physical and medical evidence, was deemed wholly credible.
Self-Defense: To invoke self-defense, appellant must prove unlawful aggression, reasonable necessity, and lack of provocation. No independent evidence corroborated any stone-throwing or stabbing attempt by Lucio. Physical evidence contradicted appellant’s version. The absence of unlawful aggression precludes any self-defense claim.
Murder Qualifying Ci
Case Syllabus (G.R. No. 217974)
Facts and Background
- On March 19, 2010 at about 9:00–9:30 p.m., Lucio Silava and his wife Victoria were in their store in Barangay San Angel, Hamtic, Antique, when accused‐appellants Rezor and Resurrecion Manzano arrived.
- The Information charged both brothers, armed with knives, of attacking, assaulting, and stabbing Lucio with treachery and abuse of superior strength, causing instantaneous death.
- The parties agreed on an inverted trial: the defense first presented evidence to establish self-defense; the prosecution then presented its own witnesses.
Procedural History
- April 17, 2012: Regional Trial Court (Branch 12, San Jose, Antique) convicted Rezor Manzano of murder, imposed reclusion perpetua, and awarded P75,000 civil indemnity, P15,000 actual expenses, P25,000 moral damages.
- October 29, 2014: Court of Appeals (Twentieth Division) affirmed the RTC decision in toto (CA-G.R. CR-HC No. 01473).
- March 5, 2018: Supreme Court issued the decision in G.R. No. 217974 resolving Rezor’s appeal.
Versions of the Parties
- Defense (Rezor Manzano):
• Lucio provoked the incident by throwing stones at Rezor’s house; a stone hit Rezor’s knee, causing him to fall.
• Lucio charged Rezor with a knife; after a struggle for the weapon Rezor “blacked out” and stabbed Lucio repeatedly.
• Rezor fled to his elder brother Reno’s house and voluntarily surrendered to police the next day. - Prosecution:
• Victoria Silava positively identified both accused stabbing her husband inside and just outside the store’s kitchen, within a well-lit fenced perimeter.
• Dr. Pacificador’s postmortem revealed fifteen stab wounds (four fatal) on Lucio’s body causing hypovolemic shock.
• Photographs of dried blood splatters inside the store and premises corroborated Victoria’s testimony.
Trial Court Findings and Ruling
- Disbelieved Rezor’s self-defense plea due to: absence of medical evidence for knee injury; improbability of black-out; inconsistency with number and location