G.R. No. 136363, September 17, 2002
JOSE C. VALLEJO, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioner Jose C. Vallejo and his brother Arturo Vallejo were charged with homicide for the stabbing death of Conner Manguiguil. The incident occurred on August 8, 1981, in a boarding house in Urdaneta, Pangasinan. The prosecution’s version, based primarily on the testimonies of eyewitnesses Sabino Mamuyac and Mario Agustin, was that after a morning drinking session involving the Vallejo brothers, the victim, and others, an argument ensued. The victim, Manguiguil, confronted the brothers in Mamuyac’s room. Petitioner Jose Vallejo then told his brother Arturo, “Ikkamon utol” (“You give him now brother.”). A fight started between Arturo and Manguiguil, during which Jose thrust a knife at Manguiguil. Manguiguil parried the knife with a kick, but Jose maintained hold of it. The witnesses left to summon their landlord. Manguiguil was later found dead with a stab wound to the chest. A bloodied, bent kitchen knife was recovered. Both prosecution witnesses initially gave sworn statements immediately after the event with some inconsistencies (e.g., on who held the knife) but testified in court that it was petitioner Jose who wielded the knife, attributing the inconsistencies to shock and fear. The defense version, presented by the accused brothers, claimed self-defense. Arturo testified that he intervened when Manguiguil was shouting at Jose. Manguiguil then punched Arturo, and a struggle ensued where Manguiguil allegedly attempted to stab Arturo with a knife. Jose intervened to help his brother, and during the struggle for the knife, Manguiguil was accidentally stabbed. The Regional Trial Court convicted Jose Vallejo of homicide, sentencing him to an indeterminate penalty and ordering him to pay damages. The Court of Appeals affirmed the conviction but modified the penalty. Petitioner Jose Vallejo appealed to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the Court of Appeals erred in affirming petitioner Jose C. Vallejo’s conviction for homicide.

RULING

The Supreme Court DENIED the petition and AFFIRMED with MODIFICATION the decision of the Court of Appeals. The Court held that the prosecution successfully proved petitioner’s guilt beyond reasonable doubt. The testimonies of eyewitnesses Sabino Mamuyac and Mario Agustin were credible and consistent on material points, establishing that petitioner Jose Vallejo stabbed the victim. The minor inconsistencies in their initial statements were satisfactorily explained as having been made under shock and did not affect their core narrative. The defense of self-defense invoked by the brothers was rejected. For self-defense to be upheld, the accused must prove by clear and convincing evidence the elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The defense failed to prove unlawful aggression on the part of the victim. The trial court’s finding that the brothers were the aggressors was supported by the evidence. The claim that the stabbing was accidental during a struggle for the knife was unconvincing, as the nature and location of the fatal wound indicated a deliberate thrust. The Court modified the penalty imposed by the Court of Appeals. For the crime of homicide under Article 249 of the Revised Penal Code, the penalty is reclusion temporal. With no mitigating or aggravating circumstances, it is imposed in its medium period. Applying the Indeterminate Sentence Law, the Supreme Court imposed an indeterminate penalty of eight (8) years and one (1) day of prision mayor as minimum to fourteen (14) years, eight (8) months and one (1) day of reclusion temporal as maximum. The awards of damages were sustained: P4,375.35 as actual damages, P50,000.00 as civil indemnity, and P50,000.00 as moral damages.