G.R. No. 135848 March 12, 2002
People of the Philippines vs. Ramonito Saure a.k.a. “Dodong”

FACTS

The prosecution established that on July 28, 1996, at a barangay benefit dance in Maasin, Southern Leyte, accused-appellant Ramonito Saure stabbed Renato Lepasanda multiple times, causing his death. Eyewitnesses Eleno Alinsub and Ernesto Lacbayo testified that after a prior verbal altercation where the victim reprimanded Saure for forcing a woman to dance, Saure later approached the seated victim from behind and stabbed him in the chest. The victim attempted to defend himself with a stool but was pursued and stabbed several more times. The witnesses emphasized the suddenness of the attack, with the victim being in a sitting position and unable to mount an effective defense.
The accused-appellant interposed self-defense, claiming the victim first attacked him with a knife after being angered by his request to dance with Arlene Lacbayo. He alleged he merely wrestled the knife away and stabbed the victim in the ensuing struggle. The trial court convicted him of murder qualified by treachery, sentencing him to reclusion perpetua and ordering him to pay civil indemnity. On appeal, Saure argued the trial court erred in rejecting his claim of self-defense and in appreciating treachery.

ISSUE

The core issue is whether the accused-appellant successfully proved self-defense and whether the qualifying circumstance of treachery was correctly appreciated to convict him of murder.

RULING

The Supreme Court affirmed the conviction. On self-defense, the Court reiterated that one who admits killing but claims justification assumes the burden of proving by clear and convincing evidence the elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The accused-appellant’s narrative failed to meet this burden. His claim that the victim was the initial aggressor was inconsistent with the number, location, and severity of the victim’s wounds, which indicated a determined assault rather than a defensive action. The testimonies of impartial eyewitnesses, who had no motive to falsely testify, were found more credible than the accused’s version.
Regarding treachery, the Court upheld its appreciation. The attack was sudden and unexpected, launched from behind while the victim was seated and oblivious. The mode of execution, employing a knife against an unarmed and unsuspecting victim, deliberately ensured the execution of the crime without risk to the assailant. This method directly and specifically ensured the victim had no opportunity for self-defense, satisfying the requirements for treachery. The Court also noted the voluntary surrender of the accused as a mitigating circumstance, but as the penalty for murder is reclusion perpetua to death and no aggravating circumstances attended the crime, the proper penalty imposed was reclusion perpetua. The award of P50,000 as civil indemnity was sustained.