G.R. No. 118091 October 3, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILFREDO VIERNES, JOEL SOSA, CORNELIO INCIANO, and ROMY PATULAY, accused-appellants.

FACTS

Accused-appellants were convicted of murder qualified by evident premeditation and aggravated by abuse of superior strength and nighttime for the killing of Herminio Doniego. The prosecution’s eyewitnesses, Sonny Doniego and Dionisio Crisostomo, testified that on the night of December 19, 1991, at a movie showing, accused Viernes stabbed the victim while co-accused Sosa, Inciano, and Patulay held him. The defense presented a different account. Accused Viernes, who initially pleaded guilty but later explained his plea, claimed self-defense. He testified that he was alone at the movie showing when the intoxicated victim, Herminio Doniego, pushed his head and later slit his back with a razor. Upon hearing a companion of Herminio say “tiroemon” (hit him), Viernes turned and stabbed Herminio in response. Viernes then fled, surrendered to the barangay captain, and later to the police. His co-accused denied participation, claiming they were elsewhere during the incident.

ISSUE

The core issues were: (1) whether accused Viernes acted in complete self-defense; (2) whether conspiracy and the aggravating circumstances of evident premeditation, abuse of superior strength, and nighttime attended the commission of the crime.

RULING

The Supreme Court REVERSED the trial court’s decision and ACQUITTED all accused-appellants. On the first issue, the Court found that Viernes successfully proved the elements of self-defense: unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The victim’s act of slashing Viernes’s back with a razor constituted a real and immediate threat to his life, satisfying unlawful aggression. The response—stabbing the aggressor—was a reasonable and necessary act to repel the attack. The Court noted the physical evidence, particularly Viernes’s wound, corroborated his narrative. Regarding the second issue, the Court found no credible evidence of conspiracy among the appellants. The prosecution witnesses gave inconsistent testimonies on material points, including the presence and specific actions of the co-accused, creating reasonable doubt. With Viernes’s claim of self-defense prevailing and the prosecution failing to prove conspiracy beyond reasonable doubt, the other accused could not be held liable. The aggravating circumstances were consequently deemed inapplicable. The Court also admonished the trial court for rendering a decision that failed to clearly state the facts and law, as constitutionally required.