Title
People vs. Roman
Case
G.R. No. 198110
Decision Date
Jul 31, 2013
Wilson Roman hacked Vicente Indaya to death at a wedding party; self-defense claim rejected, treachery proven, sentenced to reclusion perpetua, damages awarded.

Case Summary (G.R. No. 134564)

Prosecution evidence and witness accounts

Four eyewitnesses (Romero, Borlagdatan, Ebuenga, Baylon) testified they personally observed the accused hack the victim multiple times with a bolo. Their accounts consistently placed the accused behind the victim, striking at the back of the head, nape and shoulders until the victim fell and died. Borlagdatan attempted to seize the bolo and sustained a thumb injury; Baylon demonstrated the sequence in court. The necropsy report, interpreted by Dr. Pornillos, identified seven hack wounds located predominantly on the victim’s back and head, consistent with attacks from behind and inflicted by a sharp-edged instrument such as a bolo.

Defense account and testimony

The accused asserted a theory of self-defense: that the victim had threatened and then attacked him with a bolo after an earlier verbal altercation, that the accused only used his own bolo to repel the attack, and that he sustained a superficial cut to his palm during the struggle. Defense witness Tampoco corroborated that she warned the accused and that the accused seized the bolo from the victim and hacked him thereafter. There was, however, inconsistency between the accused’s account (that he drew his own bolo from the scabbard) and Tampoco’s account (that he seized the bolo from the victim).

RTC findings and judgment

The RTC found the accused guilty beyond reasonable doubt of murder. It credited the prosecution’s eyewitness testimony as identifying the accused as the perpetrator and concluded the qualifying circumstance of treachery was present because the attack was launched from behind on an unarmed and defenseless victim who had no opportunity to defend himself. The RTC rejected the self-defense plea and sentenced the accused to imprisonment (expressed erroneously as “from twenty years and one day to forty years of reclusion perpetua”) and ordered indemnity, actual and moral damages.

Court of Appeals ruling and modifications

The CA affirmed the conviction but modified the damages award: it reduced civil indemnity from P100,000 to P50,000, sustained moral damages of P50,000, deleted the RTC award of actual damages (finding lack of proof), and awarded P25,000 temperate damages plus P30,000 exemplary damages. The CA reasoned that eyewitness accounts established the accused as unlawful aggressor and emphasized the disparity in injuries (superficial cut to accused vs. seven mortal wounds to victim) as undermining self-defense.

Issues on appeal to the Supreme Court

The Supreme Court framed the principal issues as (1) whether the accused may properly invoke self-defense, and (2) whether treachery as a qualifying circumstance was established.

Parties’ positions

  • Accused: Maintained self-defense, asserting unlawful aggression by the victim, reasonable necessity to use his bolo, and lack of provocation; alternatively, argued the absence of treachery and requested conviction for the lesser offense of homicide.
  • Prosecution/OSG: Argued the accused was the unlawful aggressor; eyewitnesses and necropsy supported an attack from behind on an unarmed victim, establishing treachery and negating self-defense.

Standard of review and deference to trial courts

The Supreme Court reiterated the principle that factual findings of the RTC, when affirmed by the CA, are generally binding and will not be overturned absent clear showing of oversight or misappreciation of circumstances materially affecting the outcome. The Court afforded respect to the trial court’s credibility assessments given the presence of consistent, positive eyewitness testimony and corroborating medical evidence.

Analysis of sufficiency of evidence and credibility

The Court found the prosecution’s eyewitness testimony positive, clear, and consistent in material points: multiple witnesses observed the attack in broad daylight at a wedding, identified the accused as the assailant, and recounted that the victim was attacked from behind. The necropsy corroborated the location and fatal nature of the wounds. There was no proof of ill motive on the part of prosecution witnesses. Given this cumulative evidence, the Court concluded guilt was proven beyond reasonable doubt.

Legal elements of self-defense and application to the facts

The Court restated the tripartite elements required to establish self-defense: (a) unlawful aggression by the victim; (b) reasonable necessity of the means employed to repel it; and (c) lack of sufficient provocation by the person invoking the defense. Unlawful aggression requires actual or imminent physical force or use of a weapon and must be proven by clear and convincing evidence because self-defense is an affirmative and inherently vulnerable claim. Applying these principles, the Court found the accused failed to meet his burden: eyewitnesses consistently described the accused as the aggressor who attacked an unarmed, unsuspecting victim from behind; the disparity in injuries between the accused and victim, the location and number of wounds, the lack of proof of the victim’s initial use of a weapon, and the recovery of only one bolo at the scene undermined the accused’s narrative of self-defense. The Court therefore rejected the defense.

Treachery: legal test and Court’s application

Treachery exists when the offender employs means, methods or forms of attack that tend directly and especially to ensure execution of the crime without risk to himself, and where the victim is deprived of the opportunity to defend himself. The elements are: (1) the victim was not in a position to defend himself at the time of attack, and (2) the offender consciously adopted the particular means of attack. The Court agreed with the CA and RTC that treachery was present: the victim was attacked from behind while unarmed and unsuspecting, deprived of any real chance to defend himself, and the wounds were predominantly at the back—facts consistent with a deliberate, surprise mode of attack.

Penalty: reclusion perpetua and correction

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