Case Summary (G.R. No. 192150)
Antecedent Facts and Incident Description
On June 12, 2001, petitioner Federico Sabay and his daughter Erlinda were working on laying wood and water pipes on a property allegedly belonging to Godofredo Lopez. Godofredo confronted them, leading to a verbal altercation. During the exchange, Erlinda struck Godofredo on the head with a hard object, and Sabay threw a stone at Godofredo’s face, breaking his eyeglasses. Godofredo claimed dizziness following the incident. Subsequently, Jervie Lopez intervened to pacify the parties but was struck on the hand with a bolo by a party involved. Neighbors eventually intervened to calm the situation.
Medico-Legal Evidence and Barangay Proceedings
Medico-legal certificates dated June 12, 2001, confirmed contusions and abrasions on Godofredo Lopez and a wound on Jervie Lopez’s right palm. A complaint was filed by Godofredo and Jervie before the barangay. The parties initially agreed to settle through a Kasunduang Pag-aayos (agreement) dated June 20, 2001, based on a building inspector’s recommendation. However, the settlement was never executed as the building inspector failed to provide the promised recommendation. Consequently, the Barangay Captain issued a Certification to File an Action, allowing formal charges to proceed.
Criminal Charges and Lower Courts’ Findings
Petitioner was charged with two counts of slight physical injuries for inflicting harm on Godofredo and Jervie, and with light threats for alleged threatening behavior against Godofredo. Both petitioner and Erlinda pleaded not guilty. The Metropolitan Trial Court (MTC) convicted Federico Sabay beyond reasonable doubt for two counts of slight physical injuries, rejecting the plea of self-defense due to insufficient evidence. Light threats charges were dismissed as absorbed by the physical injuries. The Regional Trial Court (RTC) affirmed the MTC’s decision.
Petitioner’s Appeal and Court of Appeals’ Ruling
Petitioner appealed on two grounds: (1) alleged lack of MTC jurisdiction due to failure to formally offer the Certification to File an Action as evidence, and (2) erroneous dismissal of the claim of self-defense. The Court of Appeals (CA) affirmed the RTC ruling, holding that the certification was properly admitted despite the absence of formal offer because it was identified by testimony and incorporated into the records. The CA also emphasized that self-defense is a factual issue best resolved by trial courts, and found no reason to overturn their factual findings and rejection of the defense plea.
Jurisdictional Issues and Validity of Certification to File an Action
The Supreme Court ruled that the existence of the initial Kasunduan did not preclude the Barangay Captain from issuing the Certification to File an Action when the settlement was not actually implemented. The failure of the building inspector to finalize a boundary recommendation meant no effective settlement was reached. The issuance was therefore proper and presumed regular under Rule 131, Section 3(m) of the Rules on Evidence. Furthermore, the Court clarified that the conciliation procedure under Presidential Decree No. 1508 is not jurisdictional; its non-compliance does not deprive MTC of jurisdiction over the subject matter or persons involved.
Admissibility of the Certification to File an Action
Although the certification was not formally offered as required by Section 34, Rule 132 of the Rules on Evidence, the Court recognized an exception where evidence is identified via testimony and incorporated into the record. In this case, Godofredo Lopez identified and referred to the certification during cross-examination; it was marked as an exhibit and attached to the case records. Petitioner did not object at trial, validating its admissibility under the relaxed rules applicable in appropriate cases.
Evaluation of the Self-Defense Claim
The Court upheld the lower courts’ rejection of self-defense, e
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Background and Procedural History
- Petitioner Federico Sabay was charged with two counts of slight physical injuries before the Metropolitan Trial Court (MTC), Caloocan City, based on injuries inflicted on Godofredo Lopez and Jervie Lopez during a dispute.
- The complaint originated from an incident on June 12, 2001, involving a verbal altercation and physical violence on Godofredo's property where the petitioner and his daughter Erlinda were laying wood and water pipes.
- The MTC found the petitioner guilty beyond reasonable doubt but dismissed charges of light threats, considering the offense absorbed in slight physical injuries. Erlinda was absolved from light threats charges.
- The Regional Trial Court (RTC) affirmed the MTC decision, after which the petitioner appealed to the Court of Appeals (CA).
- The CA maintained the judgment of conviction, denying the petitioner's arguments concerning the absence of Certification to File an Action and his plea of self-defense.
- The Supreme Court granted the petition for review on certiorari to resolve legal questions regarding jurisdiction and evidentiary issues.
Facts of the Incident
- On June 12, 2001, petitioner and his daughter were working at Godofredo Lopez's yard when Godofredo confronted petitioner about an alleged intrusion.
- A verbal altercation escalated: Erlinda struck Godofredo on the head with a hard object, and petitioner threw a stone breaking Godofredo’s eyeglasses.
- Godofredo felt dizzy as a result of the injuries; petitioner and daughter threatened to kill him.
- Jervie Lopez intervened to pacify the parties but was hit in the hand with a bolo by petitioner.
- Neighbors later intervened to calm the situation.
- Medico-legal certificates established contusions and wounds consistent with the injuries described.
Barangay Proceedings and Certification to File an Action
- Godofredo and Jervie filed a complaint before the barangay on June 13, 2001.
- Parties agreed to a Kasunduang Pag-aayos (settlement agreement) on June 20, 2001, based on a building inspector’s recommendation which ultimately was not delivered.
- Due to the failure to resolve the dispute, the Barangay Captain issued a Certification to File an Action, authorizing the filing of charges before the MTC.
- Petitioner challenged the Certification’s validity, arguing the Kasunduan rendered it null.
Criminal Charges Filed
- Petitioner was charged with two counts of slight physical injuries for hitting Jervie and Godofredo Lopez with a bolo causing injuries requiring medical attendance of not more than seven days.
- Petitioner and his daughter were also charged with light threats for allegedly uttering threatening words against G