G.R. No. L-73605 January 29, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALEJANDRO REUNIR, accused-appellant.

FACTS

The prosecution established that on the evening of December 4, 1983, accused-appellant Alejandro Reunir, the victim Alex Umagtang, and witness Felix Ramos Jr. were together at St. Peter Memorial Chapels in Quezon City. Reunir asked for money from the victim, who initially gave some but refused a second request, causing Reunir to resent the refusal. Later, at around 1:00 AM on December 5, Ramos saw Reunir enter the house where the victim was sleeping alone. Reunir exited shortly thereafter holding a kitchen knife. The victim was found stabbed and, when asked by Ramos while being taken to the hospital, stated he did not know who stabbed him as he was asleep. The victim died from the wound. Reunir fled to Quezon province and was arrested months later.
Upon arrest, Reunir executed sworn statements admitting to stabbing the victim but claimed self-defense, alleging the victim attacked him with a knife upon being awakened. The defense presented an alibi, with Reunir and his mother testifying he was sleeping at a different location that night. The trial court convicted Reunir of Murder, appreciating treachery, and sentenced him to reclusion perpetua.

ISSUE

Whether the trial court erred in convicting the accused-appellant of Murder and in rejecting his defenses of self-defense and alibi.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The defense of self-defense was untenable as the accused failed to prove the essential elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. His flight and concealment for over two months after the incident were utterly inconsistent with the behavior of an innocent person acting in self-defense. The alibi defense likewise failed, as it was not physically impossible for him to have been at the crime scene given the proximity of his alleged location to the memorial chapels.
The Court upheld the finding of treachery (alevosia). The victim’s statement to witness Felix Ramos Jr.—that he did not know his assailant because he was asleep—was part of the res gestae and conclusively proved that the attack was sudden and from behind, offering the victim no opportunity to defend himself. This qualified the killing to Murder. However, owing to the abolition of the death penalty under the 1987 Constitution , the penalty was reduced. Applying the Indeterminate Sentence Law, the Court modified the sentence to an indeterminate penalty of ten years and one day of prision mayor, as minimum, to eighteen years, eight months and one day of reclusion temporal, as maximum.