G.R. No. 183566; May 8, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. BONIFACIO BADRIAGO, Accused-Appellant.

FACTS

Accused-appellant Bonifacio Badriago was charged with Frustrated Homicide in Criminal Case No. 4255 and Murder in Criminal Case No. 4276 before the Regional Trial Court (RTC). The charges stemmed from an incident on September 13, 2002, in Carigara, Leyte. In Criminal Case No. 4255, the information alleged that Badriago, with intent to kill, hacked Adrian Quinto with a bolo, inflicting wounds on his lumbar area and left forearm, which required medical intervention to prevent his death. In Criminal Case No. 4276, the information alleged that Badriago, with treachery and evident premeditation, attacked and stabbed Oliver Quinto with a bolo, inflicting eleven wounds which caused his death.
The prosecution presented witnesses including Adrian Quinto, who testified that while he and his brother Oliver were on a tricycle, Badriago suddenly approached and hacked him on the lumbar area and forearm. Adrian pushed Oliver off the tricycle to call for help before losing consciousness. Dr. Frederic Joseph Asanza testified that Adrian’s wounds could have been fatal without timely medical assistance. Dr. Ma. Bella Profetana testified that eight of Oliver’s eleven wounds were fatal, with hypovolemic shock as the cause of death. Victoriano Quinto, the victims’ father, testified on expenses incurred.
The defense presented accused-appellant Badriago, who claimed self-defense. He testified that Adrian and Oliver chased him with stones, bumped his pedicab, and that Adrian approached him with a knife. Badriago claimed he grabbed a bolo and struck Adrian in self-defense when Adrian attempted to stab him. He denied killing Oliver, stating he did not see him during the altercation and later ran to report the incident to the police. Defense witness Rodolfo Gabon corroborated Badriago’s account of the chase and initial confrontation, stating Adrian drew a short bolo first.
The RTC found Badriago guilty of Frustrated Murder (instead of Frustrated Homicide) and Murder, with the case elevated for automatic review.

ISSUE

The primary issue is whether the Court of Appeals correctly affirmed the RTC’s finding of guilt for Frustrated Homicide and Murder, rejecting accused-appellant’s claim of self-defense.

RULING

The Supreme Court affirmed the Decision of the Court of Appeals. The Court held that accused-appellant failed to prove self-defense by clear and convincing evidence. When self-defense is invoked, the burden of proof shifts to the accused to establish its elements: unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The Court found Badriago’s version of events unconvincing and inconsistent. His claim that Adrian was the unlawful aggressor was not credible, especially given the number, location, and severity of Oliver’s wounds, which indicated a determined assault rather than a spontaneous reaction. The nature and number of Oliver’s injuries contradicted the claim of self-defense and suggested treachery (alevosia), qualifying the killing as Murder. For the attack on Adrian, the Court agreed with the appellate court’s modification to Frustrated Homicide, as the prosecution did not establish the qualifying circumstance of treachery. The penalty and damages awarded by the Court of Appeals were sustained.