GR 193134; (March, 2016) (Digest)
G.R. No. 193134 . March 02, 2016
RAFAEL NADYAHAN, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.
FACTS
Petitioner Rafael Nadyahan was charged with Homicide for stabbing Mark Anthony Pagaddut. During trial, the defense, presenting its evidence first in a reverse trial, claimed self-defense. Nadyahan testified that on the night of the incident, he was flagged down by a group including the victim. After he refused their request to buy them drinks, one member slapped and kicked him. Seeing the group arm themselves with pieces of wood, he ran but was struck on the back. He grabbed a knife from his motorcycle and fled, but was cornered. While being hit with a belt buckle and losing consciousness, he impulsively thrust his knife, stabbing Pagaddut. He later surrendered.
The prosecution presented witnesses who portrayed Nadyahan as the aggressor, alleging he suddenly wielded a knife, chased people, and stabbed the unarmed victim. The medico-legal report showed the victim sustained three stab wounds.
ISSUE
Whether the Court of Appeals correctly affirmed the trial court’s finding of incomplete self-defense and the corresponding penalty imposed.
RULING
The Supreme Court affirmed the conviction but clarified the penalty. The trial court correctly found the elements of self-defense—unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation—were not all present. The Court agreed with the lower courts that unlawful aggression existed, initiated by the victim’s group when they attacked Nadyahan with pieces of wood and a belt buckle. This aggression did not cease when he was cornered and assaulted.
However, the means employed by Nadyahan—the use of a lethal knife to inflict multiple stab wounds—was not reasonably necessary to repel the attack. The aggression against him, while unlawful, did not justify the lethal force used, especially considering the number and location of the wounds inflicted. Therefore, only incomplete self-defense was established, which is a privileged mitigating circumstance under Article 69 of the Revised Penal Code. This reduces the penalty for homicide by one degree. With the additional ordinary mitigating circumstance of voluntary surrender, the penalty was further reduced to its minimum period. The Indeterminate Sentence Law was correctly applied, resulting in a prison term of 4 years and 2 months of prision correccional medium, as minimum, to 8 years of prision mayor minimum, as maximum.