G.R. No. 117161 March 3, 1997
RAMON INGLES @ “Monching,” petitioner, vs. THE HONORABLE COURT OF APPEALS and THE PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Ramon Ingles was charged with frustrated homicide for stabbing Celso Barreno at a cockpit in Lopez, Quezon. The prosecution’s version, as testified by Barreno, was that he was suddenly stabbed in the back by Ingles without any provocation. He turned to see Ingles about to stab him again, parried the attack, and fled before collapsing from his wounds. The attending physician testified that the stab wounds, particularly one on the arm causing profuse bleeding, could have been fatal without timely medical intervention.
Ingles admitted to the stabbing but pleaded self-defense. He claimed that Barreno, after a prior altercation over land, first attempted to stab him with a fan knife on the cockpit balcony. Ingles stated he evaded the thrust, wrestled the knife away, and then used it against Barreno, hitting him in the arm and later in the back as Barreno retreated. The Regional Trial Court convicted Ingles of the lesser crime of attempted homicide, a ruling affirmed by the Court of Appeals.

ISSUE

Whether the petitioner acted in complete self-defense to exempt him from criminal liability.

RULING

The Supreme Court denied the petition and modified the penalty. The Court held that the plea of self-defense failed. When an accused admits the act, the burden shifts to him to prove the concurrence of all elements of self-defense: unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The Court found that even assuming Barreno initiated an attack, any unlawful aggression ceased the moment Ingles disarmed him and seized the knife. By then stabbing Barreno—first in the arm and then, notably, giving chase to stab him in the back—Ingles became the aggressor. His actions exceeded the reasonable necessity required for self-preservation.
Furthermore, his subsequent conduct—fleeing the scene, discarding the knife in a well, and surrendering to an army officer instead of the policemen present—belied his claim of innocent defense. The Court also found that treachery attended the commission of the crime, as the victim was stabbed in the back, depriving him of a chance to defend himself. Although not alleged in the information to qualify the crime to murder, treachery was properly appreciated as a generic aggravating circumstance. Thus, the crime committed was frustrated homicide, not attempted homicide. Considering the aggravating circumstance of treachery and the mitigating circumstance of voluntary surrender, the Court imposed an indeterminate sentence of four years and two months of prision correccional, as minimum, to eight years and one day of prision mayor, as maximum.