G.R. No. 107747 October 20, 1997
The People of the Philippines, plaintiff-appellee, vs. Arnold Talingting @ Anol, accused-appellant.

FACTS

On the night of December 21, 1990, accused-appellant Arnold Talingting and his friends attended a dance in Barangay San Jose. At the dance, Talingting called 15-year-old Rosalia Linggo “very cheap” after she danced with his friend, causing her to cry. The victim, Dario Cuyno, approached Rosalia to console her and patted her shoulders. Later, while Cuyno was urinating, Talingting suddenly appeared and stabbed him once in the left chest with a hunting knife. Eyewitness Armando Barmuel saw Talingting pull the knife from Cuyno’s chest and flee. The victim was taken to a pumpboat where, before losing consciousness, he gave an antemortem statement to Pfc. Armando Palatan, identifying Talingting as his assailant and affixing a thumbprint in his own blood. The victim died from the wound. Talingting surrendered to a barangay tanod and later admitted to police that he stabbed Cuyno. At trial, Talingting invoked self-defense, claiming Cuyno collared him from behind while with four companions, and one said, “This is our chance, pards,” prompting him to make a blind, backward stab to free himself. The Regional Trial Court convicted him of murder and sentenced him to reclusion perpetua.

ISSUE

Whether the trial court erred in convicting accused-appellant of murder, specifically concerning the credibility of prosecution witnesses and the validity of his claim of self-defense.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court found no reason to overturn the trial court’s assessment of witness credibility, noting the prosecution witnesses’ testimonies were candid, categorical, and consistent, and corroborated by physical evidence. The claim of self-defense failed because accused-appellant did not prove the essential element of unlawful aggression by the victim. His story that the victim and four companions surrounded him was deemed implausible, especially as his own witness did not seek help. The killing was qualified by treachery (alevosia), as the attack was sudden and unexpected, giving the victim no chance to defend himself. The Court found the mitigating circumstance of voluntary surrender. Applying the Indeterminate Sentence Law, the penalty was modified to an indeterminate sentence of ten (10) years and one (1) day of prision mayor as minimum to twenty (20) years of reclusion temporal as maximum. The civil indemnity of P50,000.00 was affirmed.