G.R. No. 127089 November 19, 2004
RAFAEL RENDON, petitioner, vs. PEOPLE OF THE PHILIPPINES and INOCENCIA D. MAGRARE, respondents.

FACTS

Petitioner Rafael Rendon and his wife Teresita were charged with murder for the death of Rodolfo Magrare. The prosecution alleged that on October 28, 1989, in Barangay Bia-an, Hamtic, Antique, the spouses, conspiring and helping each other, attacked Rodolfo with a bolo and spear, causing his instantaneous death. After trial, the Regional Trial Court convicted Rafael of homicide, not murder, and Teresita of slight physical injuries. The court sentenced Rafael to an indeterminate prison term, considering the mitigating circumstance of voluntary surrender.
Rafael appealed to the Court of Appeals, raising self-defense. He claimed that the victim, Rodolfo Magrare, blocked his path, asked him why he was smiling, and then suddenly grabbed the bolo sheathed at his waist. A struggle ensued, and during the scuffle, Rodolfo fell and was hit on the neck by the bolo. The Court of Appeals, however, affirmed the trial court’s conviction, giving credence to the prosecution’s eyewitness account that Rafael initiated the assault.

ISSUE

Whether the Court of Appeals erred in affirming Rafael Rendon’s conviction for homicide by rejecting his claim of self-defense and by relying on the factual findings of the trial court.

RULING

The Supreme Court denied the petition and affirmed the conviction. The Court emphasized that appeals by certiorari under Rule 45 of the Rules of Court are limited to questions of law; factual findings of the trial court, especially when affirmed by the Court of Appeals, are generally conclusive and binding. The petitioner’s arguments essentially sought a re-evaluation of the evidence, which is not the function of the Supreme Court in such petitions.
On the substantive claim of self-defense, the Court reiterated the settled doctrine that when an accused invokes self-defense, the burden of proof shifts to him to establish by clear and convincing evidence the elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The petitioner relied on the strength of his own evidence, which the trial and appellate courts found insufficient and less credible than the consistent testimony of the prosecution eyewitness. The Court found no cogent reason to disturb the lower courts’ uniform assessment of witness credibility and their conclusion that the petitioner failed to prove self-defense. The claim regarding an alleged irregularity in the trial being held in chambers was also dismissed, as the records showed no objection from counsel and no evidence of infringement of the accused’s rights.