G.R. No. 152133 ; February 9, 2006
Rollie Calimutan, Petitioner, vs. People of the Philippines, et al., Respondents.

FACTS

Petitioner Rollie Calimutan was charged with homicide for allegedly throwing a stone at Philip Cantre, hitting his back. The incident occurred on February 4, 1996, after Cantre, who had been drinking, punched Calimutan’s companion, Michael Bulalacao, suspecting him of a prior stoning of his house. The prosecution’s eyewitness, Rene Sañano, testified that Calimutan threw a fist-sized stone at Cantre’s back. Cantre went home, complained of pain, and died the following morning. The initial post-mortem by the municipal health officer cited cardio-respiratory arrest due to suspected food poisoning. Subsequently, the victim’s family requested an exhumation and autopsy by the NBI, which found a lacerated spleen and massive internal hemorrhage, concluding the cause of death was traumatic injury to the abdomen.
The defense presented Calimutan as its sole witness. He claimed he acted in self-defense, alleging that Cantre was the unlawful aggressor who pulled out a knife and threatened him. Calimutan testified that he merely picked up a stone to defend himself when Cantre charged at him, and the stone accidentally hit Cantre. The Regional Trial Court convicted Calimutan of homicide, a decision affirmed by the Court of Appeals.

ISSUE

Whether the Court of Appeals erred in affirming Calimutan’s conviction for homicide, specifically concerning the credibility of the eyewitness account, the cause of death, and the validity of his claim of self-defense.

RULING

The Supreme Court denied the petition and affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the assessment of witness credibility is best undertaken by the trial court. The testimony of prosecution eyewitness Sañano was found credible, consistent, and sufficient to establish that Calimutan intentionally threw the stone that hit the victim. The Court gave greater weight to the detailed NBI autopsy report, which medically established the causal link between the stoning and the fatal laceration of the spleen, over the initial municipal health officer’s report.
Regarding self-defense, the Court ruled that Calimutan failed to prove the essential elements by clear and convincing evidence. His claim of unlawful aggression by the victim, who allegedly wielded a knife, was not corroborated and was contradicted by the credible prosecution witness. The Court found that the physical evidence and circumstances did not support a finding that Calimutan faced an imminent danger that justified his use of force. Consequently, his guilt for the crime of homicide was proven beyond reasonable doubt. The Court modified the damages awarded, increasing the civil indemnity and granting moral and exemplary damages.