G.R. No. 130941 ; August 3, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PONCIANO AGLIPA, accused-appellant.

FACTS

The prosecution’s evidence established that on April 24, 1995, in Malabuyoc, Cebu, an altercation arose after the goats of spouses Solano and Severina Macion damaged the corn plants of the Aglipa family. The Macions went to the barangay captain’s house to report the incident. There, appellant Ponciano Aglipa appeared and repeatedly challenged Solano Macion to a fight, which Solano initially ignored. Later, as the Macions were walking home, Aglipa and his family again shouted challenges from their house. While Solano was urinating near a store, Aglipa suddenly emerged and struck him on the back of the head with an iron bar, causing his instantaneous death. Aglipa then also struck Severina, who was holding a lamp, inflicting serious injuries.
The defense, presenting its evidence first due to its claim of self-defense, offered a different account. Aglipa testified that Solano Macion was the unlawful aggressor who attacked him with a bolo while he was on his way home. He claimed he merely defended himself by parrying the blows and accidentally hitting Macion with an iron bar he was carrying. He asserted he acted out of fear for his life.

ISSUE

Whether the accused-appellant Ponciano Aglipa has successfully proven his claim of self-defense to exculpate himself from the crimes of Murder and Frustrated Murder.

RULING

No. The Supreme Court affirmed the conviction. When an accused invokes self-defense, the burden of proof shifts to him to establish by clear and convincing evidence the concurrence of three requisites: unlawful aggression by the victim, reasonable necessity of the means employed to repel it, and lack of sufficient provocation on the defender’s part. By pleading self-defense, the accused admits authorship of the killing, making conviction inevitable if he fails to prove these elements.
The Court found Aglipa’s claim of self-defense untenable. First, he failed to prove unlawful aggression. The prosecution witnesses credibly testified that the unarmed victim, Solano Macion, was urinating with his back turned when Aglipa launched a sudden and unexpected attack with a deadly weapon. This act constituted treachery, qualifying the killing to murder. Second, the nature and number of fatal wounds inflicted on the victim, and the subsequent attack on Severina, negated any reasonable necessity of the means employed for defense. The trial court’s assessment of witness credibility is accorded great respect, and the defense failed to show any reason to overturn its findings. Consequently, the defense of self-defense must fail. The penalty for Murder was affirmed as reclusion perpetua, while the penalty for Frustrated Murder was modified to an indeterminate sentence.