G.R. No. L-70392 June 30, 1986
People of the Philippines, plaintiff-appellee, vs. Regino Camilet, defendant-appellant.

FACTS

The prosecution’s evidence established that on the evening of July 2, 1982, Barangay Captain Perfecto Camancho, Sr., responding to his nephew’s report of an assault, led a group to investigate. While walking along a road in Leon, Iloilo, the accused, Regino Camilet, suddenly emerged from a grove of banana plants and, without any warning, stabbed Camancho, Sr. with a one-foot-long knife. The victim exclaimed that Camilet had stabbed him before succumbing to a fatal wound in the inguinal region. The defense presented a starkly different version, claiming self-defense. Camilet testified that the Camancho family waylaid him, with Perfecto, Sr. hitting him with a hammer and his son Sherwin striking him with an air rifle. He claimed he only swung his knife blindly while being led away by his wife, unaware he had hit and killed the victim.

ISSUE

The core issue is whether the trial court erred in convicting Camilet of murder and rejecting his claim of self-defense.

RULING

The Supreme Court affirmed the conviction but modified the crime from murder to homicide. The Court found Camilet’s claim of self-defense utterly devoid of merit. His testimony that he carried a long knife at night for farming purposes was deemed incredible, as such tasks are not performed after dark. The physical evidence and the credible, consistent testimonies of the prosecution eyewitnesses convincingly established that Camilet was the unlawful aggressor who launched a sudden and fatal attack on the victim. However, the qualifying circumstance of treachery was not proven. The fatal frontal wound indicated the victim was facing his assailant at the start of the assault, negating the element of a deliberate and sudden attack from behind without risk to the attacker. Evident premeditation was also not established, as there was no proof of the time Camilet determined to commit the crime or acts showing he clung to that determination. Nighttime and disregard of rank were not considered aggravating, as there was no proof they were deliberately sought or that the crime was committed in contempt of the victim’s official position. In the absence of any qualifying circumstance, the killing constituted homicide. Applying the Indeterminate Sentence Law, Camilet was sentenced to an indeterminate penalty of eight years and one day of prision mayor medium as minimum to sixteen years of reclusion temporal medium as maximum, and ordered to pay an indemnity of P30,000 to the victim’s heirs.