G.R. No. 108784 September 13, 1994
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ADJUTOR TANDUYAN alias “Bot”, accused-appellant.

FACTS

The prosecution’s evidence established that on the evening of July 30, 1990, in Malita, Davao del Sur, accused-appellant Adjutor Tanduyan entered a store where his uncle, Benjamin Tanduyan, was sleeping on a counter. After asking a companion to confirm the victim’s identity, appellant left briefly and returned brandishing a knife. He then repeatedly stabbed the sleeping and unsuspecting Benjamin in the presence of a 13-year-old eyewitness, Juvel Rellon. The victim died from multiple stab wounds, with the fatal injury severing his carotid artery. Appellant fled after threatening the eyewitness not to tell anyone.
The defense presented a starkly different version. Appellant claimed self-defense, alleging that the victim, who had stabbed him three years prior, suddenly attacked him with a knife that night. Appellant asserted he managed to wrestle the knife away and stabbed Benjamin during the struggle. He denied the presence of the prosecution’s eyewitnesses, claiming the store was closed and the area deserted at the time of the incident.

ISSUE

Whether the trial court correctly convicted accused-appellant of Murder, rejecting his plea of self-defense.

RULING

The Supreme Court affirmed the conviction for Murder. The Court upheld the trial court’s assessment of witness credibility, giving full weight to the clear, consistent, and credible testimony of the young eyewitness, Juvel Rellon. The defense of self-defense was correctly rejected as it was not proven by clear and convincing evidence. For self-defense to succeed, the accused must establish unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. Here, appellant’s own narrative was illogical and inconsistent with the physical evidence.
The Court found appellant’s account inherently improbable. His claim that he was suddenly attacked yet had the presence of mind to disarm the victim, pick up the knife, and then stab him in a manner that produced wounds primarily on the victim’s back defied the natural sequence of a spontaneous fight. The location and number of wounds, particularly the fatal wound from behind, were more consistent with a deliberate assault on a defenseless victim than a sudden struggle. Furthermore, the swift identification and arrest of appellant shortly after the incident contradicted his claim that the area was deserted. These facts, coupled with the positive identification by a credible eyewitness, established the killing was attended by treachery (alevosia), as the victim was attacked while asleep and unable to defend himself, thereby qualifying the crime as Murder.