G.R. No. 138782 , September 27, 2002
People of the Philippines, Plaintiff-Appellee, vs. Jerry Villegas, Accused-Appellant.

FACTS

In the evening of March 28, 1997, Paz Mendoza accompanied her husband, Jaime Mendoza, to buy cigarettes at a store in Barangay Masaya, Bay, Laguna. As Jaime was walking back towards Paz after his purchase, accused-appellant Jerry Villegas suddenly emerged from the dark and stabbed Jaime with a foot-long knife, hitting him on the left side of the body. Jaime fell. His brother, Dominique, who was nearby, heard Paz’s shouts for help and rushed over. As Dominique attempted to carry Jaime, accused-appellant attacked him with the knife. Dominique fled, picked up a stone, threw it at accused-appellant, and caused him to flee. Jaime was brought to the hospital where he died from the stab wound. Accused-appellant surrendered to the barangay captain and police authorities. He was charged with Murder. During trial, accused-appellant interposed self-defense, claiming that Jaime had threatened him earlier, fired shots at his house, and shot him in the arm, prompting him to stab Jaime in retaliation. The Regional Trial Court convicted accused-appellant of Murder, sentenced him to reclusion perpetua, and ordered him to pay damages. Accused-appellant appealed.

ISSUE

1. Whether the trial court erred in not appreciating the justifying circumstance of self-defense.
2. Whether the trial court erred in giving full credence to the prosecution witness’s testimony and disregarding the defense’s evidence.
3. Whether the crime committed was Murder or only Homicide.

RULING

The Supreme Court affirmed the conviction with modification to the damages awarded.
1. On Self-Defense: The Court ruled that accused-appellant failed to prove the elements of self-defense by clear and convincing evidence. When an accused admits the killing and pleads self-defense, the burden of proof shifts to him. He must prove: (a) unlawful aggression; (b) reasonable necessity of the means employed; and (c) lack of sufficient provocation. The core element of unlawful aggression was not established. The defense’s evidence, including a medical certificate for a gunshot wound, was deemed dubious as the attending physician was not presented, the signatures were questionable, and no bullet holes or empty shells were found at the scene. The mere fact of a wound does not prove self-defense or negate being the aggressor.
2. On Credibility of Witnesses: The Court found no reason to disturb the trial court’s assessment of the credibility of prosecution witness Paz Mendoza. Minor inconsistencies in her testimony regarding the time of the stabbing did not affect her credibility on the essential fact of the killing. The trial court’s findings on witness credibility are generally accorded great respect.
3. On the Crime Committed: The Court upheld the conviction for Murder, qualified by treachery. The attack was sudden and unexpected, ensuring the victim had no opportunity to defend himself. The means of execution were deliberately adopted to accomplish the crime without risk to the accused. Evident premeditation and nighttime were not proven. The penalty of reclusion perpetua was correctly imposed, considering the mitigating circumstance of voluntary surrender.
4. On Damages: The Court modified the damages. The award of civil indemnity of P50,000.00 was affirmed. The award of actual damages was reduced to P20,350.00, as only this amount was substantiated by receipts. Exemplary damages of P25,000.00 were additionally awarded due to the presence of the qualifying circumstance of treachery.