G.R. No. 114032 February 22, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. IGNACIO CAMAHALAN, AURELIO TABACON and PABLITO TOCMO, accused. IGNACIO CAMAHALAN and AURELIO TABACON, accused-appellants.

FACTS

Anatalio Lor died on the evening of 25 March 1988 due to multiple stab and lacerated wounds. Accused Ignacio Camahalan, Aurelio Tabacon, and Pablito Tocmo were charged with murder. The Regional Trial Court acquitted Pablito Tocmo but found Ignacio Camahalan guilty as principal and Aurelio Tabacon as accomplice, crediting Camahalan with voluntary surrender. Both were sentenced to imprisonment and ordered to pay indemnity. On appeal, the Court of Appeals found both appellants guilty as principals of murder, sentenced each to reclusion perpetua, increased the indemnity to P50,000.00, and ruled Camahalan was not entitled to voluntary surrender. The case was certified to the Supreme Court for final determination.
The prosecution evidence, primarily from witness Roberto Sarol, established that on the evening of 25 March 1988, the victim Anatalio Lor was invited to drink by the appellants. Without warning, Aurelio Tabacon stabbed Lor, and Ignacio Camahalan hacked him. Lor ran away but was chased and overtaken by Camahalan, who stabbed him in the back and continued stabbing him after he fell. The post-mortem examination revealed eleven stab wounds, six of which were fatal.
The appellants admitted the killing but raised the defenses of self-defense (Camahalan) and defense of a stranger (Tabacon). They claimed Lor was the aggressor, challenging Camahalan to a fight, hacking plants and the house, and trying to force his way inside. Camahalan claimed he stabbed Lor in self-defense during the struggle, and Tabacon claimed he intervened upon seeing Camahalan drenched in blood and struggling with Lor.

ISSUE

The main issues revolve around the credibility of the prosecution witness, the validity of the appellants’ defenses, and whether their guilt was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the decision of the Court of Appeals. It held that the appellants failed to prove their respective defenses of self-defense and defense of a stranger by clear, satisfactory, and convincing evidence. The Court found the appellants’ version incredulous, noting that the deceased sustained eleven stab wounds while the appellants emerged without any injury, and that Camahalan’s claim of being drenched in blood was unsupported by evidence. The Court found the testimony of prosecution witness Roberto Sarol credible and entitled to full faith and credit. The Court also ruled that Camahalan was not entitled to the mitigating circumstance of voluntary surrender, as his surrender was not spontaneous but occurred after the police had questioned witnesses. The penalty of reclusion perpetua and the award of P50,000.00 as civil indemnity were sustained.