G.R. No. 132750; December 14, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ELGER GUZMAN, accused-appellant.

FACTS

The prosecution’s case, primarily through eyewitness Lolito Aquino, established that on November 18, 1995, during a wedding party in Ilagan, Isabela, the victim Elmer Aquino approached accused-appellant Elger Guzman. Elmer asked if they could talk elsewhere, but Guzman replied they should talk where they were. Without any prior physical altercation, Guzman then stabbed Elmer in the chest with a fan knife, causing his death. The autopsy confirmed a fatal stab wound. The defense presented a contrary version, with Guzman claiming he acted in self-defense. He testified that Elmer tried to stab him first with a kitchen knife, and during a struggle for the weapon, Elmer was accidentally stabbed. Defense witness Leonard Angangan corroborated the claim of an initial aggressive act by the victim.

ISSUE

The core issue is whether the trial court correctly rejected the claim of self-defense and found accused-appellant Elger Guzman guilty of murder qualified by treachery.

RULING

The Supreme Court affirmed the conviction for murder. The legal logic hinges on the settled principle that an accused who invokes self-defense admits to the killing and assumes the burden of proving its justifying circumstances by clear and convincing evidence. The Court found that Guzman failed to discharge this burden. His claim of an unprovoked attack by the victim was not credible, as it was contradicted by the positive and categorical testimony of prosecution eyewitness Lolito Aquino, who was merely two meters away and saw no such aggression. The physical evidence also undermined the defense; the single, fatal stab wound was inconsistent with a story of a accidental stabbing during a struggle. Furthermore, Guzman’s flight after the incident and his surrender only three days later were contrary to the behavior of an innocent person. However, the Court modified the trial court’s ruling on the qualifying circumstance. Treachery was not established because the prosecution evidence showed the victim had approached the appellant, initiating a face-to-face confrontation. This foreclosed any finding that the attack was deliberately and consciously adopted to ensure its execution without risk to the assailant. Consequently, the crime was homicide, not murder. The penalty was reduced, and the awarded damages were recalculated accordingly.