G.R. No. 106102 October 29, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARMANDO SARABIA, accused-appellant.

FACTS

On March 16, 1991, at the Murcia Transloading Station in Negros Occidental, accused-appellant Armando Sarabia suddenly barged into the office where Edward Liza and eyewitness Joelouie Dolorosa were present. Without any warning, Sarabia, armed with a bolo or “ginunting,” hacked Liza multiple times. Dolorosa, fearing for his life, fled and hid in a nearby cane car where he informed another co-worker, Raul Villanueva, of the attack. The station was well-lighted by powerful searchlights, allowing Dolorosa a clear view of the incident. The victim sustained eight wounds, including six hack wounds and one stab wound, leading to his death as certified by Dr. Emmanuel Bando.
At trial, the prosecution presented Dolorosa’s eyewitness account and the medico-legal findings. The defense, however, interposed self-defense. Sarabia claimed that Liza, his kumpadre, had invited him for a drink and later attacked him with a knife, forcing him to retaliate. The Regional Trial Court of Bacolod City rejected this defense, convicted Sarabia of Murder qualified by treachery, and sentenced him to reclusion perpetua. Sarabia appealed, insisting on self-defense and challenging the credibility of the prosecution’s eyewitness.

ISSUE

The core issue is whether the trial court erred in convicting the accused-appellant of Murder, thereby rejecting his claim of self-defense.

RULING

The Supreme Court affirmed the conviction. The legal logic rests on the fundamental principle that an accused who invokes self-defense admits to the killing and consequently bears the burden of proving, by clear and convincing evidence, the justifying circumstances of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The Court found that Sarabia failed to discharge this burden. His testimony was uncorroborated and inconsistent with the physical evidence. The nature, location, and number of wounds inflicted—eight wounds, including a near-severing of the neck and a stab wound penetrating the lung—were excessive and indicative of a determined assault, negating any claim of reasonable necessity or a purely defensive act. The attack was sudden and unexpected, with the victim given no opportunity to defend himself, which validly qualified the killing as Murder through treachery. The Court also upheld the trial court’s assessment of witness credibility, emphasizing that the firsthand account of eyewitness Dolorosa, who had a clear view under well-lighted conditions, was more credible than the accused’s self-serving testimony. The award for loss of income was deleted for lack of sufficient basis, but the conviction and the penalty of reclusion perpetua, along with the award for civil indemnity, were sustained.