G.R. No. 248130 , December 02, 2020
Prudencio Ganal, Jr. y Badajos, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner Prudencio Ganal, Jr. was charged with Homicide for shooting Julwin Alvarez. The prosecution’s version alleged that after a dispute with the victim’s nephew, Angelo, the petitioner armed himself, and when Julwin later approached his house, petitioner shot him multiple times. The defense, however, presented a narrative of self-defense and defense of a relative. They testified that on the night of the incident, an intoxicated Angelo, after being refused entry to a drinking session, later returned with his uncle Julwin. The duo hurled stones at the petitioner’s house, with Julwin forcibly entering the gate, assaulting and knocking unconscious the petitioner’s father, Ganal, Sr., with a stone. Petitioner, from his doorway, saw Julwin—armed with stones and a knife—advancing menacingly towards him. Petitioner fired a warning shot, but Julwin continued his advance. When Julwin was about two to three meters away, petitioner, fearing for his life, shot him. After the shooting, petitioner immediately called the police, surrendered, and turned over his firearm.

ISSUE

Whether the petitioner acted in valid self-defense, thereby exempting him from criminal liability for the killing of Julwin Alvarez.

RULING

Yes, the Supreme Court acquitted the petitioner on the ground of the justifying circumstance of self-defense. The Court emphasized that when self-defense is invoked, the burden of proof shifts to the prosecution to disprove the accused’s claim beyond reasonable doubt. The Court found the prosecution failed to meet this burden. The evidence clearly established the element of unlawful aggression on the part of the victim. Julwin, armed with stones and a knife, had already violently attacked and rendered the petitioner’s father unconscious. He then advanced towards the petitioner in a threatening manner, ignoring a warning shot. This constituted a real, imminent, and continuous danger to the petitioner’s life. The Court rejected the lower courts’ finding that the number of gunshot wounds negated self-defense. The reasonableness of the accused’s belief in the necessity of his action is judged based on the circumstances as they appeared to him at that critical moment. Faced with a determined and armed aggressor who persisted despite being shot, the petitioner’s perception of a “kill or be killed” situation was reasonable. Therefore, the elements of self-defense—unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation—were satisfactorily proven, warranting acquittal.