GR 229349; (January, 2020) (Digest)
G.R. No. 229349 , January 29, 2020
People of the Philippines, Plaintiff-Appellee, v. Greg Antonio y Pableo @ Tokmol, Accused-Appellant.
FACTS
Accused-appellant Greg Antonio y Pableo was charged with Frustrated Murder (Crim. Case No. 06-246909) and Murder (Crim. Case No. 06-246310) for the stabbing incidents on August 15, 2006, in Manila. The prosecution alleged that after a fight between the victim, Arthuro Villalobos, and the accused’s sister, Lorna, Antonio approached Villalobos, placed an arm around his shoulders, and stabbed him multiple times. An eyewitness, David Fresado, testified to this sequence. The defense, presented solely by Antonio, claimed he acted in self-defense and defense of his relative. He testified that Villalobos and his companions were beating Lorna, and when he intervened, Villalobos drew a knife and lunged at him; Antonio wrestled the knife away and used it to stab Villalobos. The Regional Trial Court acquitted Antonio of Frustrated Murder but convicted him of Murder, finding his claim of self-defense unproven and appreciating treachery and evident premeditation. The Court of Appeals affirmed the murder conviction but found evident premeditation not proven, while increasing the moral damages.
ISSUE
Whether the Court of Appeals erred in finding accused-appellant Greg Antonio y Pableo guilty beyond reasonable doubt of murder.
RULING
The Supreme Court denied the appeal and affirmed the conviction for murder. The Court held that when an accused invokes a justifying circumstance like self-defense, the burden of proof shifts to the accused to establish its elements by clear and convincing evidence. Antonio failed to prove unlawful aggression, a requisite for both self-defense and defense of a relative. His testimony was inconsistent and uncorroborated, whereas the prosecution eyewitness credibly testified that the attack was sudden and unexpected. The Court found that treachery attended the killing, as Antonio employed means that ensured the execution of the crime without risk to himself from Villalobos’s defense, qualifying the homicide as murder. The Court modified the awarded damages in line with prevailing jurisprudence, granting civil indemnity, moral damages, exemplary damages, and temperate damages to the victim’s heirs.