G.R. No. 105580 May 17, 1994
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANIEL QUIÑO, accused-appellant.

FACTS

On the evening of December 29, 1989, in Poblacion, Danao, Bohol, Dioscoro Quiño was found dead with two stab wounds. His son, Daniel Quiño, fled the scene, surrendered to police, and was later charged with parricide. During arraignment, Daniel pleaded not guilty, invoking self-defense. The prosecution presented only one witness, Dra. Benita Mar y Tan, who conducted the post-mortem examination, finding a fatal penetrating stab wound on the left chest and another on the left buttock. The victim’s widow and a neighbor, who had given earlier statements, could not be presented in court. The defense presented Daniel, who testified that he went to his father’s house to borrow a carabao. His father, allegedly drunk, refused, got a piece of wood, and beat him. Daniel ran to the rice paddies, pursued by his father. When caught and beaten again, he fell, pulled out a hunting knife, and swung it from side to side to fend off the attacks, after which his father fell. He then drew the knife and ran away. Defense witnesses Paterno Melecio partly corroborated the initial altercation, and Zenon Acaba testified about the family’s lack of interest in pursuing the case. The Regional Trial Court found Daniel guilty of parricide and sentenced him to reclusion perpetua, indemnity, and costs.

ISSUE

Whether the accused-appellant, Daniel Quiño, has successfully proven the justifying circumstance of self-defense to exculpate himself from the crime of parricide.

RULING

No. The Supreme Court affirmed the trial court’s decision, finding the accused guilty of parricide. When an accused admits the killing and invokes self-defense, the burden of proof shifts to him to establish the elements by clear and convincing evidence. The essential elements of self-defense are: (a) unlawful aggression; (b) reasonable necessity of the means employed; and (c) lack of sufficient provocation. The Court agreed with the lower court that unlawful aggression was not proven. The accused did not sustain any injuries despite the alleged repeated blows with a piece of wood, and his testimony that he merely swung his knife from side to side was inconsistent with the deep, penetrating nature of the fatal chest wound. Material inconsistencies in his testimony, such as whether he was lying down or standing when he used the knife, further undermined his credibility. The nature and number of the victim’s wounds, and the fact that the accused sustained no injury, belied the claim of self-defense. Therefore, the plea of self-defense failed, and the conviction for parricide under Article 246 of the Revised Penal Code was upheld.