G.R. No. 126125; March 9, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARMANDO GAVIOLA, accused-appellant.

FACTS

The prosecution’s case rested solely on the eyewitness account of Albert Fernandez, son of the victim Antonio Fernandez. Albert testified that on the night of July 29, 1994, he heard a noise outside his house. Upon investigation, he saw accused-appellant Armando Gaviola hack his father with a bolo on the right forearm, causing Antonio to fall. Eduardo Gaviola then stabbed the fallen victim. When accused-appellant attempted to attack Albert, a patrol car arrived, prompting the assailants to flee. Antonio died three days later from his injuries. In his defense, Armando Gaviola claimed he acted in self-defense. He alleged he intervened in a fight to help a fellow tricycle driver, Tommy Mihiyo, who was being mauled by Antonio and Albert. He claimed that after pacifying them, the Fernandezes returned armed and attacked him, forcing him to wrest a scythe from Antonio and use it in self-defense.

ISSUE

The core issue is whether the trial court erred in convicting accused-appellant of murder based on the lone eyewitness testimony and in rejecting his claim of self-defense.

RULING

The Supreme Court affirmed the conviction but modified the award of damages. The trial court’s reliance on Albert Fernandez’s testimony was upheld. The Court emphasized that factual findings of the trial court, especially on witness credibility, are accorded great respect and finality unless arbitrariness is shown. Albert testified in a straightforward manner, and his account was consistent with the medical findings and his prior affidavit. His relationship to the victim did not impair his credibility; rather, it lent credence to his desire to see justice served. In contrast, the Court found accused-appellant’s claim of self-defense untenable. By invoking self-defense, he assumed the burden of proving unlawful aggression, reasonable necessity of the means employed, and lack of provocation. His narrative was deemed incredible and unsupported, especially by the failure to present Mihiyo as a witness. The number and location of the victim’s wounds also contradicted a claim of mere self-defense. The Court agreed with the trial court that the qualifying circumstances of treachery and evident premeditation were not proven. However, the crime was properly qualified as murder due to abuse of superior strength, as the two armed assailants attacked a defenseless and older victim with excessive force. The award for actual damages was increased to P19,297.00 based on substantiated receipts.