G.R. No. 28450 , August 8, 1928
PEOPLE OF THE PHILIPPINE ISLANDS vs. MORO SALAHUDDIN (alias SALA)

FACTS

On the morning of September 29, 1926, Moro Aru returned to his house with severe bruises on his head and face. Before he died a few hours later, he made a dying declaration to his wife and two witnesses (Haili and Lakibul). He stated that while he was at the river, the appellant Salahuddin (alias Sala) and two others (Baturani and Hamahali) attacked him. Salahuddin struck him on the forehead, causing him to fall, and the assailants continued to beat him until he lost consciousness. The attending physician confirmed that Aru died from a cerebral hemorrhage due to blows to the head. Prior incidents revealed a motive: Aru had previously fought with Salahuddin, who lost a tooth, and Aru’s father-in-law had accused the other two of theft. Salahuddin was convicted of homicide, while his co-accused were acquitted. On appeal, Salahuddin claimed self-defense, alleging that Aru attacked him first with a bolo over a dispute about a carabao ruining his field, and he merely retaliated with a stick.

ISSUE

Whether the trial court correctly convicted Salahuddin of homicide, rejecting his claim of self-defense.

RULING

Yes, the conviction is affirmed. The Supreme Court upheld the trial court’s finding that the killing constituted homicide and correctly rejected the plea of self-defense.
* Validity of the Conviction: The conviction was primarily based on the credible dying declaration of the victim, Aru, which identified Salahuddin as one of his attackers. The Court found this declaration admissible as it was made under a consciousness of impending death, which was realized shortly thereafter. This was corroborated by Salahuddin’s own statement to a constabulary officer implying a motive for revenge.
* Rejection of Self-Defense: The Court found Salahuddin’s claim of self-defense unproven and improbable. The evidence contradicted his story: (1) he allegedly dodged a bolo attack yet sustained no wounds; (2) his claim of delivering only one blow was inconsistent with the multiple contusions found on both sides of the victim’s head; and (3) the location and number of injuries could not be explained merely by a fall into shallow water. The Court emphasized that self-defense must be established by credible and convincing evidence, which was lacking in this case.
The penalty of twelve years and one day of *reclusion temporal* and an indemnity of P1,000 was affirmed as within the trial court’s discretion.