G.R. No. L-74485-86; July 30, 1987
The People of the Philippines, plaintiff-appellee, vs. Efren Garufil, defendant-appellant.

FACTS

The accused, Efren Garufil, along with Diosdado Tek and Nestor Sitol, were charged with Murder and Frustrated Murder for the stabbing of Ronilo Desanta and Erinio Badian while they were asleep inside a parked jeep. The trial court acquitted Tek and Sitol due to insufficient evidence of conspiracy but convicted Garufil. The prosecution’s case rested primarily on the testimony of the surviving victim, Erinio Badian. He testified that he awoke feeling a warm sensation on his stomach, discovered he was bleeding, stood up, and saw Garufil jumping from the jeep holding a knife, while Tek and Sitol were seen running away. The defense, however, presented a different version. Garufil claimed he acted in self-defense, alleging that Desanta and Badian had earlier attacked him with fists and a piece of wood near the seashore, and that he stabbed them only after being cornered with his back against a drum during the struggle.

ISSUE

The core issue is whether the trial court correctly rejected Garufil’s claim of self-defense and found him guilty of the crimes charged beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The legal logic hinges on the settled doctrine that self-defense is an affirmative allegation, and the burden of proof rests upon the accused to establish its elements by clear and convincing evidence. The Court found Garufil’s narrative of self-defense inherently improbable and unsupported by the evidence. The trial court correctly noted the physical improbability of his story, wherein he claimed to have been weakened by blows yet managed to subdue two attackers and drag them a significant distance. Furthermore, his claim of shouting for help in a quiet area at night, which went unheard, undermined his credibility. The Court also upheld the trial court’s finding that Garufil’s conduct after the incident indicated flight rather than a voluntary surrender, which is inconsistent with the behavior of an innocent person acting in self-defense. The positive identification by eyewitness Badian, who had no ill motive to falsely testify, prevailed over the uncorroborated and dubious claim of self-defense. The acquittal of the co-accused for lack of conspiracy did not exculpate Garufil, as the evidence conclusively pointed to him as the direct perpetrator of the stabbings.