G.R. No. 140680 ; May 28, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. RENY DE LOS REYES, appellant.

FACTS

The appellant, Reny de los Reyes, was charged with murder for stabbing Felomeno Omamos to death on January 13, 1998, in Naawan, Misamis Oriental. Upon arraignment, he pleaded guilty but invoked self-defense, leading to a reverse trial. The prosecution’s version, primarily through the testimony of the victim’s wife Annaliza, established that the appellant, while on a bicycle, suddenly and without provocation stabbed the unarmed Felomeno from behind multiple times as the victim was walking with his young son. Annaliza witnessed the attack and shouted for help.
The defense presented a contrasting narrative. The appellant claimed that Felomeno first threatened him, then later threw a stone at his bicycle, causing him to fall. He alleged that Felomeno then attacked him with a knife, and he merely wrested the weapon away and used it in self-defense. After the incident, the appellant surrendered to the police.

ISSUE

The core issue is whether the appellant successfully proved the essential elements of self-defense to exculpate himself from the charge of murder.

RULING

The Supreme Court affirmed the conviction for murder but modified the awarded damages. The Court ruled that the appellant failed to discharge his burden of proving the elements of self-defense by clear and convincing evidence. When an accused admits the killing but pleads self-defense, the onus shifts to him to prove the justifying circumstance. The requisites of self-defense are: (1) unlawful aggression by the victim; (2) reasonable necessity of the means employed to prevent or repel it; and (3) lack of sufficient provocation on the part of the person defending himself.
The Court found the appellant’s claim of unlawful aggression unconvincing and inconsistent with the physical evidence and credible testimonies. The prosecution evidence showed a sudden, treacherous attack from behind on an unarmed victim, negating any prior aggression from Felomeno. The number, location, and severity of the stab wounds, coupled with the appellant’s flight and subsequent surrender, were more indicative of a determined assault rather than a spontaneous defense. The trial court’s assessment of witness credibility, which favored the prosecution’s straightforward account over the appellant’s improbable story, was accorded great respect. Consequently, the justifying circumstance of self-defense was not established. The qualifying circumstance of treachery was duly proven, as the mode of attack ensured the victim had no opportunity to defend himself. The penalty of reclusion perpetua was affirmed, with civil indemnity, moral damages, and temperate damages awarded to the victim’s heirs.