G.R. No. 170462 , February 5, 2014
RODOLFO GUEVARRA and JOEY GUEVARRA, Petitioners, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioners Rodolfo Guevarra and his son Joey Guevarra were charged with Frustrated Homicide and Homicide for hacking and stabbing brothers Erwin and David Ordonez on November 8, 2000, in Alicia, Isabela. The prosecution’s version, based on the testimony of surviving victim Erwin Ordonez, stated that while he, his brother David, and a companion were passing by the petitioners’ compound, they were suddenly attacked. Erwin claimed he was hacked by Rodolfo and then dragged inside the compound where both petitioners continued to assault him, inflicting thirteen wounds. He denied that they threw stones or damaged property. David died from his injuries. The petitioners interposed self-defense, claiming that the victims, along with a companion, forcibly entered their compound, destroyed their gate and tricycle, threw stones at their house, and that David threatened to kill Rodolfo and hacked at him first. Rodolfo claimed he parried the blow and then retrieved a bolo to defend himself and his son. Their neighbor, Balbino Agustin, corroborated their account of the initial aggression. The Regional Trial Court convicted the petitioners, disbelieving their claim of self-defense due to inconsistencies in their testimonies and a failure to prove unlawful aggression. The Court of Appeals affirmed the conviction but modified the damages awarded.

ISSUE

Whether the petitioners have successfully proven the justifying circumstance of self-defense to exonerate them from criminal liability for Frustrated Homicide and Homicide.

RULING

No. The Supreme Court affirmed the decisions of the lower courts, holding that the petitioners failed to prove the essential element of unlawful aggression required for self-defense. The Court emphasized that when an accused invokes self-defense, the burden of proof shifts to them to establish by clear and convincing evidence the justifying circumstance. Unlawful aggression must be actual, imminent, and a real threat to life or personal safety. The Court found that the alleged acts of the victims—shouting challenges, throwing stones, and damaging property—did not constitute unlawful aggression sufficient to justify the lethal force used by the petitioners, especially since the petitioners were inside their home and could have sought help or retreated. Furthermore, the nature, number, and location of the wounds inflicted on the victims (Erwin sustained 13 wounds; David suffered about 10 fatal wounds) were inconsistent with a mere act of defense and indicated a determined homicidal aggression. The Court modified the damages, awarding civil indemnity, moral damages, and temperate damages to the victims and their heirs, with interest.