G.R. No. L-23514 February 17, 1970
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AVELINO MANANSALA, JR., ET AL., defendants, AVELINO MANANSALA, JR. and JOSE MANANSALA, defendants-appellants.

FACTS

On March 27, 1962, between 1:00 and 2:00 PM, a quarrel occurred inside the New Bicol Carinderia near the Legaspi Port Market. The protagonists, including appellants Avelino Manansala, Jr. and Jose Manansala and the victim Rodrigo Aringo, came out through the backdoor. Jose Manansala held Rodrigo in a tight embrace from behind, rendering him helpless. While Rodrigo was in this position, Avelino stabbed him multiple times with a balisong, continuing the attack even after Jose forced Rodrigo down onto a nearby bamboo bed. Police arrived to find Avelino still holding the knife and Rodrigo’s body on the bed. Rodrigo died from massive hemorrhage and shock due to thirteen wounds before reaching the hospital. The prosecution presented eyewitnesses Celestino Atun and Percival Amador. The defense, through witnesses Domingo Daria and Salvador Petilos, claimed self-defense, alleging that Rodrigo, a baggage boy, first demanded payment from Avelino, a textile peddler, and then fist-fought him. When a knife fell from Avelino’s pocket, Rodrigo allegedly got a kitchen knife and attempted to stab Avelino, prompting Jose to embrace Rodrigo to stop him, at which point Avelino stabbed Rodrigo. The trial court convicted both of murder, crediting Avelino with the mitigating circumstance of sufficient provocation.

ISSUE

The main issues are whether the appellants acted in self-defense, whether the crime was committed with treachery qualifying it as murder, and the correct criminal liability and penalties for each appellant.

RULING

The Supreme Court modified the trial court’s decision. It held that Avelino Manansala, Jr. did not act in legitimate self-defense, as he sustained no wounds and the alleged knife used by the victim was never presented. The killing was qualified by treachery because the victim was helplessly held by Jose. However, the mitigating circumstance of sufficient provocation (the victim’s fist blows) was correctly appreciated for Avelino. He is guilty as principal of murder and sentenced to an indeterminate penalty of 10 years and 1 day of prision mayor to 17 years, 4 months, and 1 day of reclusion temporal, and to indemnify the heirs in the increased amount of P12,000.00. Jose Manansala is not liable as a co-principal, as there was no prior agreement to kill. His initial act of embracing the victim was to stop the fistfight, but he became liable as an accomplice because he continued to hold the victim after the first knife thrust, facilitating the multiple wounds. As an accomplice to murder, he is sentenced to an indeterminate penalty of 4 years, 2 months, and 1 day of prision correccional to 12 years and 1 day of reclusion temporal and is subsidiarily liable for the indemnity in case of Avelino’s insolvency. The judgment is affirmed in all other respects.