G.R. No. 131851 . February 22, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALFREDO BASADRE, accused-appellant.

FACTS

On September 2, 1995, Dionesa Naguio found her common-law husband, Tirso Naguio, drinking with accused-appellant Alfredo Basadre and others. After a playful incident where Basadre pretended to slash Tirso with a bolo, Tirso and Dionesa left upon the urging of Basadre’s brother. While walking home, Dionesa heard a whistle and saw Basadre emerge near a coconut tree, clutching a bolo. Without provocation, Basadre attacked Tirso, hacking him multiple times on the shoulders, forearms, and knees. Despite Tirso’s pleas, Basadre proceeded to stab him in the chest and abdomen and repeatedly hack his back, inflicting seventeen fatal wounds. Dionesa shouted for help and later reported the crime to the barangay chairman.
Basadre surrendered to authorities, yielding the bloodied bolo, but later claimed self-defense at trial. He testified that he was on his way home when he met Tirso, who allegedly rushed at him with bad intentions in the dark, forcing him to draw his bolo and stab Tirso in the chest. He admitted to then hacking and stabbing the fallen victim multiple times to “finish him off.”

ISSUE

Whether the trial court correctly convicted accused-appellant Alfredo Basadre of Murder, rejecting his claim of self-defense.

RULING

The Supreme Court affirmed the conviction for Murder. The Court meticulously dismantled the claim of self-defense, noting that an accused invoking it admits to the killing and must prove by clear and convincing evidence the justifying circumstances of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. Basadre’s testimony failed on all counts. His claim that a drunk and unarmed Tirso suddenly rushed at him in the dark was inherently improbable and unsupported by evidence. Crucially, his admission to continuing the attack on a fallen and helpless victim—hacking and stabbing him seventeen times—utterly negated any claim of reasonable necessity and instead revealed a determined intent to kill.
The Court upheld the finding of treachery (alevosia), qualifying the killing as Murder. The attack was sudden and unexpected, executed in a manner that insured its execution without risk to Basadre. Tirso, who was intoxicated and walking home with his wife, had no opportunity to defend himself against Basadre, who had lain in wait and initiated the assault with a lethal weapon. The mitigating circumstance of voluntary surrender was appreciated, warranting the penalty of reclusion perpetua. The award of civil indemnity was also sustained.