G.R. No. 132251; July 6, 2000
People of the Philippines, plaintiff-appellee, vs. Raelito Librando, Larry Surdillas and Eddie Purisima, accused-appellants.

FACTS

On December 11, 1996, Edwin Labandero, his eight-year-old daughter Aileen, and a relative, Fernando de los Santos, were walking home in Barangay Bunga, Don Salvador Benedicto, Negros Occidental. They encountered accused-appellants Raelito Librando, Larry Surdillas, and Eddie Purisima on a trail. Without warning, Raelito struck Edwin with a piece of wood, and Eddie delivered another blow. Edwin attempted to flee but was chased and cornered by the three men, who took turns beating him with wooden pieces until he fell and died. Aileen, illuminated by a torch her father was carrying, clearly witnessed the attack. Fernando took Aileen and reported the incident to barangay officials. The postmortem examination revealed Edwin died from cerebral hemorrhage due to extensive head injuries consistent with an assault by multiple persons.
The accused-appellants presented a different version, claiming Edwin was the aggressor. They alleged that an intoxicated Edwin, angered after Raelito refused him a loan earlier that day, ambushed and swung a piece of wood at them. They contended they merely acted in self-defense. After trial, the Regional Trial Court of Bacolod City convicted them of murder qualified by abuse of superior strength and sentenced them to reclusion perpetua.

ISSUE

Whether the guilt of accused-appellants for the crime of murder was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimony of the child eyewitness, Aileen Labandero, to be credible, straightforward, and consistent. Her identification of the three accused was positive and reliable, given the illumination from the torch. The defense of self-defense was correctly rejected by the trial court. For this defense to prosper, the accused must prove unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. Here, the nature, number, and location of the fatal wounds on the victim—primarily on the head, inflicted by three men with wooden poles—were grossly disproportionate to the claimed single act of aggression by the victim. This disproportionality negated self-defense and instead indicated a concerted effort to kill, constituting abuse of superior strength which qualified the killing to murder. The Court modified the civil liability, increasing the award for loss of earning capacity to ₱659,992.50 based on a proper computation of the victim’s life expectancy and net income.