G.R. No. 158057 - Toledo vs. People

Case Summary (G.R. No. 158057)

Facts Surrounding the Incident

On the evening of September 16, 1995, the petitioner, Noe Toledo, returned home to Tuburan, Odiongan, and observed a group including the victim, Ricky F. Guarte, drinking gin noisily near his home. After requesting them to keep quiet, petitioner went inside and slept. Later, Ricky and his companions returned and were stoned by the petitioner. Upon confrontation, petitioner allegedly stabbed Ricky with a bolo, resulting in the latter’s death due to massive blood loss from stab wounds to the thoraco-abdominal region.

Evidence Presented by the Prosecution

The prosecution demonstrated that the petitioner had a bolo specially made on the day of the incident. Witness testimonies established that Ricky and his group were drinking and that petitioner threw stones at their house, inciting confrontation. Ricky approached the petitioner’s house unarmed to inquire about the stoning; petitioner then stabbed him unexpectedly. Medical evidence corroborated the fatal injuries and cause of death.

Petitioner’s Defense

The petitioner claimed that the stabbing was accidental while defending himself from an aggressive, intoxicated Ricky, who allegedly brandished a balisong and threatened him. Petitioner admitted to holding the bolo but insisted the wound inflicted was unintentional during Ricky’s forceful push of his door. He later voluntarily surrendered to authorities.

Trial Court’s Findings and Judgment

The Regional Trial Court of Odiongan found the petitioner guilty of homicide with mitigating circumstance of voluntary surrender, sentencing him to an indeterminate penalty from six years and one day to twelve years and one day of imprisonment, along with civil liability for damages to victim’s heirs. The court disbelieved petitioner’s testimony of accidental stabbing as uncorroborated and inconsistent with physical and testimonial evidence.

Appellate Court Ruling

The Court of Appeals affirmed the trial court’s decision, rejecting the petitioner’s argument that the stabbing was accidental under Article 12, paragraph 4 of the Revised Penal Code. It also held that petitioner failed to prove complete self-defense as a justifying circumstance under Article 11, paragraph 1, emphasizing the absence of unlawful aggression by the victim.

Legal Issue on Appeal

The sole issue was whether the petitioner was guilty beyond reasonable doubt of homicide or if he had proven exemption from criminal liability either by accident or self-defense.

Analysis on Theories of Defense

The petitioner initially argued accident without fault (Article 12, Paragraph 4), then shifted to assert complete self-defense (Article 11, Paragraph 1). The Supreme Court held that a party cannot change defensive theories on appeal, particularly when the theories are mutually exclusive. Accident presupposes absence of intent and freedom from negligence, while self-defense requires a deliberate act responding to unlawful aggression.

Nature of Accident and Self-Defense under the Revised Penal Code

Accident (Article 12, Paragraph 4) requires performing a lawful act with due care, causing injury without fault or intention. Self-defense (Article 11, Paragraph 1) requires proof of unlawful aggression, reasonable necessity of means employed, and lack of provocation. Both are affirmative defenses burdened with clear and convincing evidence.

Evaluation of Petitioner’s Evidence

The petitioner’s testimony was found incredible and lacking in probative value. Key points undermining it included: lack of evidence of door damage or petitioner’s injury; improbability that an accidental bolo st

Case Syllabus (G.R. No. 158057)

Background and Procedural History

The case involves Noe Toledo y Tamboong, the petitioner, who was charged with homicide before the Regional Trial Court (RTC) of Odiongan, Romblon.
The petitioner was accused of unlawfully stabbing Ricky F. Guarte on September 16, 1995, causing his death.
The RTC convicted the petitioner of homicide and sentenced him to an indeterminate penalty of prision mayor minimum to reclusion temporal minimum, along with ordering payment of civil liability to the victim’s heirs.
The petitioner appealed to the Court of Appeals (CA), which affirmed the RTC’s decision while denying the motion for reconsideration.
The petitioner then filed a petition for review to the Supreme Court contending errors by the CA and sought acquittal on grounds of self-defense.

Facts of the Case

On the day of the incident, the petitioner saw Ricky Guarte and his friends drinking near his house and requested them to refrain from making noise.
Later that evening around 9:00 p.m., Ricky and his companions were heard throwing stones at the Guarte family’s house.
Ricky confronted the petitioner at his doorstep, asking why he was stoning their house.
The petitioner stabbed Ricky with a bolo during this encounter, causing a fatal abdominal wound.
Medical evidence confirmed that Ricky died from massive blood loss due to the stab wound, with injuries penetrating vital organs.
The petitioner testified that his stabbing of Ricky was accidental when Ricky forcedfully pushed open the door and threatened to stab him with a balisong.
He claimed to have acted in lawful defense and accidentally hit Ricky while defending himself, subsequently surrendering to authorities.

Issues Presented

The primary legal question is whether the petitioner is criminally liable for homicide or if he acted either by accident exempting him from liability under Article 12, paragraph 4 of the Revised Penal Code (RPC), or in self-defense justifying his act under Article 11, paragraph 1 of the RPC.
Whether the petitioner’s claim of accidental killing or self-defense is supported by clear and convincing evidence to exempt or justify his liability for the victim’s death.

Petitioner’s Defense Arguments

Initially, the petitioner argued that the stabbing was an accident occurring during a lawful act performed with due care, thus exempt from liability under Article 12, paragraph 4.
The petitioner later asserted he acted in complete self-defense, citing the essential elements: unlawful aggression, reasonable means employed, and lack of provocation.
He claimed that Ricky threatened him with a balisong and forcibly pushed the door, necessitating defensive action with his bolo.
He argued that the bolo unintentionally struck Ricky in the stomach as Ricky lost his balance, supporting the accidental nature of the injury.
The petitioner emphasized that he voluntarily surrendered and sought to nega