GR 172871; (September, 2008) (Digest)
G.R. No. 172871, September 16, 2008
People of the Philippines vs. Clemente Casta y Carolino
FACTS
The prosecution charged appellant Clemente Casta with murder for stabbing Danilo Camba on August 20, 1989, in Bolinao, Pangasinan. Eyewitness Marlyn Cister testified she saw the appellant suddenly appear from behind the victim and stab him. Another eyewitness, Modesto Cardona, corroborated this, stating he was walking with the victim when the appellant emerged from behind and attacked Danilo with a knife. The autopsy report confirmed the victim died from stab wounds to the back and forearm. The appellant surrendered the following day.
The appellant presented a different account, claiming he was merely buying fish when an unknown person (later identified as Danilo) called, boxed at him, and grappled with him. He alleged he only noticed his knife was bloody after the struggle, implying self-defense. He also contested the admissibility of his extrajudicial confession.
ISSUE
Whether the appellant is guilty beyond reasonable doubt of the crime of murder, qualified by treachery.
RULING
Yes, the Supreme Court affirmed the appellant’s conviction for murder. The Court found the testimonies of the prosecution eyewitnesses credible, consistent, and sufficient to establish guilt. Both witnesses clearly narrated how the appellant, without warning, attacked the victim from behind, ensuring the victim had no opportunity to defend himself. This manner of attack constituted alevosia or treachery, qualifying the killing as murder.
The Court rejected the appellant’s claim of self-defense. For self-defense to prosper, the accused must prove unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The appellant’s own narrative failed to establish unlawful aggression, as he admitted the alleged boxing attempt did not hit him, and his claim of a sudden grapple was uncorroborated. His flight after the incident and surrender further undermined his defense. The positive identification by credible witnesses prevails over his bare denial. The penalty of reclusion perpetua was affirmed, with modifications to the awarded damages.