G.R. No. 131840; April 27, 2000
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NILO BAUTISTA and HENRY BAUTISTA, accused-appellants.

FACTS

The prosecution’s evidence established that on June 7, 1995, in Tanay, Rizal, the victim Igmidio Grajo was pursued by accused-appellants Henry and Nilo Bautista. Igmidio ran inside a house to evade them but was chased outside. Henry, armed with a balisong, stabbed Igmidio multiple times while Nilo restrained Igmidio’s son, Richard Grajo, who attempted to intervene. Igmidio died from his wounds. The prosecution presented eyewitnesses, including Richard, to this sequence of events.
The defense, principally through Henry’s testimony, claimed self-defense. Henry alleged that the drunk victim initially assaulted him with a lead pipe. He further claimed that during a struggle, he wrested a knife from Igmidio, who had gotten it from a parked tricycle, and used it to stab the victim. Nilo claimed he merely arrived to pacify Henry. The trial court rejected the defense version, finding the testimonies of the prosecution witnesses credible, and convicted both accused of Murder qualified by treachery.

ISSUE

The core issue is whether the trial court correctly convicted the accused-appellants of Murder, and relatedly, whether the justifying circumstance of self-defense or the qualifying circumstance of treachery was sufficiently proven.

RULING

The Supreme Court modified the conviction from Murder to Homicide. The Court upheld the trial court’s rejection of the plea of self-defense. For self-defense to prosper, the accused must prove unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The Court found Henry’s narrative incongruous with the physical evidence. The number, location, and trajectory of the victim’s wounds—multiple stab wounds to the chest and back—were inconsistent with a spontaneous, defensive struggle and instead indicated a determined attack. The claim that the victim was the initial aggressor who produced a knife was deemed an afterthought.
However, the Court ruled that treachery was not proven beyond reasonable doubt. The prosecution evidence showed that the attack was not deliberately and consciously adopted to ensure the execution without risk to the assailant. The initial pursuit and the victim’s attempt to flee indicated a face-to-face confrontation. The attack did not come suddenly and unexpectedly from behind in a manner that totally deprived the victim of any chance to defend himself. Absent any qualifying circumstance, the crime is Homicide. The Court sentenced Henry to an indeterminate penalty and Nilo to a slightly higher maximum term due to the aggravating circumstance of abuse of superior strength, as he held back the victim’s son. Both were ordered to pay civil indemnity, moral damages, and actual damages, with Nilo additionally liable for exemplary damages.