G.R. No. 132568; February 6, 2002
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MATT G. CAMPOMANES and EDWIN D. ROSITA, accused-appellants.

FACTS

On December 30, 1994, at Rizal Park, security guard Renante Aureada witnessed accused Matt Campomanes chase and grapple with fellow photographer Loreto Alkonga. As Aureada attempted to intervene, accused Edwin Rosita arrived, drew a fan knife, and initially threatened Aureada before turning to the victim. Aureada saw Campomanes holding Alkonga’s arms while Alkonga was seated on the ground, rendering him defenseless, and Rosita proceeded to stab him multiple times. The two accused then fled but were apprehended. Alkonga died from multiple stab wounds. The prosecution presented Aureada’s eyewitness account and corroborating police and medico-legal testimony.
The accused proffered a different narrative, claiming incomplete self-defense. Rosita alleged that Alkonga was the initial aggressor, attacking him with a camera and a knife, and that he only wrested the knife and stabbed Alkonga during a struggle. Campomanes claimed he was merely trying to pacify the two when he was hit and lost consciousness. The trial court rejected these defenses, convicted both of Murder qualified by treachery, and sentenced them to reclusion perpetua.

ISSUE

Whether the accused-appellants are guilty of Murder, qualified by treachery, beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimony of eyewitness Aureada credible, consistent, and corroborated by physical evidence. His account clearly established that the attack was sudden and that the victim, Alkonga, was restrained by Campomanes and seated on the ground when Rosita stabbed him. This manner of attack ensured that Alkonga could not put up any defense, thereby qualifying the killing with treachery. The essence of treachery is the deliberate adoption of means that deprive the victim of any opportunity for self-defense, which was present here.
The Court rejected the claim of incomplete self-defense. For such a defense to prosper, the accused must prove unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The accused failed to prove unlawful aggression on the part of the victim. Their version was inconsistent and uncorroborated, and the nature and number of the victim’s wounds were disproportionate to a mere defensive response. The trial court’s assessment of witness credibility is accorded great respect, and no compelling reason was shown to overturn its findings. Thus, the guilt of both appellants for Murder was proven beyond reasonable doubt.