G.R. No. 212565 , February 25, 2015.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. BENJAMIN CASAS y VINTULAN, Accused-Appellant.

FACTS

Two Informations were filed before the Regional Trial Court (RTC) of Pasig City charging accused-appellant Benjamin Casas with the Murder of Joel Tabile and the Frustrated Murder of Eligio Ruiz. The incidents occurred on December 24, 2007, in San Juan City. The prosecution’s version established that Casas, accompanied by another person, went to a taho factory looking for someone. Not finding his target, he brandished a knife. Eligio Ruiz, an employee, confronted him. A fistfight ensued between Eligio and Casas. During the melee, Casas took the knife from his companion and stabbed Eligio twice while Eligio was fleeing. Casas then encountered Joel Tabile, who tried to help Eligio using a bamboo pole. Joel slipped, fell prostrate, and Casas stabbed him twice. Casas then overtook Eligio and stabbed him again. Eligio hit Casas with a plastic stool, forcing him to drop the knife. Police officers later arrested Casas, who admitted to stabbing someone. During trial, after the prosecution rested, Casas filed a demurrer to evidence, which was denied. The defense then changed its theory, with Casas admitting the stabbings but interposing self-defense, claiming Joel attacked him with a knife first and that he acted to protect himself. The RTC convicted Casas of Murder for killing Joel and Attempted Homicide for injuring Eligio. The Court of Appeals affirmed the conviction but modified the damages awarded. Casas appealed to the Supreme Court.

ISSUE

Whether or not Casas’s conviction for the crimes of Murder and Attempted Homicide should be upheld.

RULING

The Supreme Court partly granted the appeal. It upheld Casas’s conviction but modified the crime concerning Eligio Ruiz from Attempted Homicide to Frustrated Homicide.
The Court found that Casas failed to prove the justifying circumstance of self-defense. Upon invoking self-defense, he assumed the burden of proving its elements—unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation—by clear and convincing evidence. The evidence showed Casas was the aggressor: he wielded the knife, initiated the attack on Eligio, stabbed Joel while he was prostrate, and pursued and stabbed Eligio again. His injuries (abrasions, a contusion, and incised wounds) were not life-threatening and did not indicate unlawful aggression from the victims. Thus, the essential element of unlawful aggression was absent.
For the killing of Joel Tabile, the Court affirmed the Murder conviction. Treachery was present as Casas stabbed Joel twice when the latter had slipped, fallen, and was lying prostrate and defenseless.
For the injuries to Eligio Ruiz, the Court modified the conviction from Attempted Homicide to Frustrated Homicide. The prosecution proved Casas performed all acts of execution to kill Eligio, as shown by his use of a deadly weapon, the number and location of wounds inflicted, and his resolve to chase and stab the fleeing victim. The crime did not consummate due to timely medical assistance, a cause independent of Casas’s will. The absence of qualifying circumstances rendered the crime Frustrated Homicide, not Frustrated Murder.
The awards of damages were modified in accordance with prevailing jurisprudence.