G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. Reyes

FACTS

Accused-appellant Juan Dela Cruz was charged with the crime of Murder under Article 248 of the Revised Penal Code for the killing of Pedro Santos. The prosecution alleged that on January 15, 2015, in Quezon City, Dela Cruz, with treachery and evident premeditation, attacked Santos with a bladed weapon, causing his death.

During trial, the prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz suddenly stab Santos from behind without any provocation. The defense, on the other hand, interposed self-defense, claiming that Santos was the aggressor and that Dela Cruz merely acted to protect himself.

The Regional Trial Court (RTC) convicted Dela Cruz of Murder, appreciating the qualifying circumstance of treachery. The Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal.

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ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the qualifying circumstance of treachery was properly appreciated.
3. Whether the accused’s claim of self-defense is credible.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.

The Court found the testimony of eyewitness Maria Reyes credible, consistent, and corroborated by physical evidence. Her positive identification of Dela Cruz as the perpetrator, coupled with the medico-legal report confirming the fatal nature of the wounds, established his guilt beyond reasonable doubt.

2. The qualifying circumstance of treachery was properly appreciated.

Treachery exists when the offender employs means, methods, or forms in the execution of the crime that tend directly and specially to ensure its execution, without risk to himself arising from the defense the victim might make. The sudden attack from behind, without warning, deprived Santos of any opportunity to defend himself. Hence, treachery qualified the killing to Murder.

3. The claim of self-defense is without merit.

For self-defense to prosper, the accused must prove by clear and convincing evidence: (a) unlawful aggression on the part of the victim; (b) reasonable necessity of the means employed to prevent or repel it; and (c) lack of sufficient provocation on the part of the person defending himself.

Dela Cruz failed to prove unlawful aggression. His version was uncorroborated and inconsistent with the physical evidence, which showed that Santos was stabbed from behind. The nature, number, and location of the wounds also negated self-defense, indicating a determined effort to kill rather than repel an attack.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan Dela Cruz for Murder is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.