GR 238455; (December, 2020) (Digest)
G.R. No. 238455 , December 09, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ROLANDO AGUILA Y ROSALES, ACCUSED-APPELLANT.
FACTS
Accused-appellant Rolando Aguila was charged with Murder for stabbing Delfin Sayat during a wedding reception on January 6, 2002. The prosecution’s eyewitness, Cristina Sayat Tanang, testified that she saw her uncle, Rolando, who appeared drunk and was holding a bolo, approach her seated grandfather, Delfin, from behind. She shouted a warning, but Rolando stabbed Delfin twice. Delfin died from hypovolemic shock secondary to the stab wounds. The defense interposed self-defense. Rolando claimed that when he approached the group where Delfin was drinking, Delfin stood up, cursed him, and drew a gun. Fearing for his life, Rolando drew a fan knife and stabbed Delfin. His brother, Renato, corroborated that Delfin drew a gun, which he pushed away, causing a commotion.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of accused-appellant Rolando Aguila for Murder, qualified by treachery, and properly rejected his claim of self-defense.
RULING
The Supreme Court affirmed the conviction for Murder but modified the damages. The Court upheld the rejection of self-defense. For this justifying circumstance to prosper, the accused must prove by clear and convincing evidence the concurrence of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. Here, Rolando failed to prove unlawful aggression. The testimony of his brother, Renato, was inconsistent and unreliable as he admitted he did not see the actual stabbing due to the commotion. The Court found the prosecution’s version more credible. An eyewitness clearly saw Rolando approach the unsuspecting, seated victim from behind and stab him. This mode of attack, executed suddenly and without warning, deprived Delfin of any opportunity to defend himself or retaliate, thereby qualifying the killing with treachery. The Court also noted the victim was 76 years old, but this was not alleged in the Information and thus could not be considered as an aggravating circumstance. The award of damages was modified in line with prevailing jurisprudence, granting civil indemnity, moral damages, and exemplary damages for Murder, all with legal interest.