G.R. No. 120549, April 04, 1997
People of the Philippines, Plaintiff-Appellee, vs. Enriquito Unarce, Accused-Appellant.

FACTS

The prosecution’s evidence established that on November 16, 1992, the victim, Gaspar Narrazid, was drying palay near his house. The accused-appellant, Enriquito Unarce, who was Narrazid’s son-in-law, suddenly approached from behind and without warning hacked him with a bolo on the left side of his face. As the wounded victim fell, the accused-appellant continued to hack him multiple times on his arm and knees. An eyewitness, Roy Odin, intervened by throwing a stone at the accused-appellant, who then fled. The victim died hours later from massive hemorrhage due to the incised wounds.
The accused-appellant invoked self-defense, claiming the victim and two nephews ambushed him, stoned him, and that the victim attempted to hack him first. He asserted that he merely parried the attacks, which resulted in the victim’s injuries. After the incident, he reported to the police and surrendered. The trial court rejected this version, finding him guilty of murder qualified by treachery and sentenced him to reclusion perpetua.

ISSUE

Whether the trial court erred in convicting the accused-appellant of murder and in rejecting his claim of self-defense.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the inherent weakness of the claim of self-defense. When an accused invokes self-defense, the burden of proof shifts to him to establish its elements by clear and convincing evidence. The Court found the accused-appellant’s narrative inherently improbable and physically inconsistent with the objective evidence. The nature, location, and number of the victim’s wounds—including a deep, fatal wound to the face fracturing the cheekbone and cutting the tongue, and other wounds to the arm and knees—negated a scenario of mere parrying or defense. Such multiple, severe injuries indicated a determined assault, not a spontaneous, reflexive act of protection.
Furthermore, the Court upheld the finding of treachery. The attack was sudden, from behind, while the victim was bent over and unarmed, offering no opportunity for defense or retaliation. This manner of execution directly ensured the execution of the crime without risk to the aggressor. The Court also ruled that the mitigating circumstance of voluntary surrender could not alter the penalty, as reclusion perpetua is an indivisible penalty imposed in its full duration regardless of attendant circumstances. Thus, the conviction for murder was sustained.