G.R. No. 179035; April 16, 2008
THE PEOPLE OF THE PHILIPPINES, appellee, vs. JESUS PAYCANA, JR., appellant.

FACTS

Appellant Jesus Paycana Jr. was charged with the complex crime of parricide with unintentional abortion for killing his seven-month pregnant wife, Lilybeth. The prosecution evidence, including the eyewitness account of appellant’s own daughter, Angelina, established that on November 26, 2002, appellant, a butcher, arrived home carrying his tools. Without provocation, he strangled and stabbed his wife fourteen times. Angelina witnessed the attack and begged her father to stop. The victim’s father, Tito, heard screams and saw his daughter lying mortally wounded. The autopsy confirmed the cause of death as multiple stab wounds leading to organ failure.
At trial, appellant admitted killing his wife but claimed self-defense. He alleged that after a prior altercation, he told his wife they should separate. As he was leaving, she allegedly stabbed him first, and he wrested the knife and stabbed her in retaliation. The defense presented medical testimony suggesting appellant’s wounds could have been self-inflicted. The Regional Trial Court convicted appellant, a decision affirmed by the Court of Appeals, prompting this automatic review.

ISSUE

Whether the trial court erred in not appreciating the justifying circumstance of self-defense in favor of the appellant.

RULING

The Supreme Court affirmed the conviction. The Court ruled that appellant failed to discharge the burden of proving self-defense by clear and convincing evidence. An accused who invokes self-defense admits the killing and must prove the concurrence of unlawful aggression by the victim, reasonable necessity of the means employed to repel it, and lack of sufficient provocation. Unlawful aggression is indispensable. Here, the claim was belied by the credible and consistent testimony of eyewitness Angelina, which was part of the res gestae, corroborated by Tito and the medical findings. The number and nature of the victim’s fourteen stab wounds negated any reasonable necessity and indicated a determined effort to kill, not defend. The trial court’s factual findings, including its assessment of witness credibility, are accorded great weight and were upheld. Consequently, appellant was correctly found guilty of the complex crime of parricide with unintentional abortion. The penalty imposed was reclusion perpetua, in accordance with Republic Act No. 9346 prohibiting the death penalty.