G.R. No. 200800 , February 9, 2015
People of the Philippines, Plaintiff-Appellee, vs. Oscar Sevillano y Retanal, Accused-Appellant.

FACTS

Accused-appellant Oscar Sevillano y Retanal was charged with Murder for the death of Pablo Maddauin. The prosecution witnesses, Jose Palavorin and Carmelita Cardona, testified that on March 11, 2007, while they and the victim were seated on a bench conversing, the appellant, who appeared drunk, approached and without warning stabbed the victim in the chest. Despite attempts to restrain him, appellant continued to stab the victim several more times. The victim was brought to the hospital but died the same day. The appellant interposed self-defense, claiming the victim was the armed aggressor who stepped on his injured foot and attempted to stab him, and that the victim was accidentally stabbed during a struggle for the knife. The Regional Trial Court (RTC) found appellant guilty of Murder qualified by treachery and sentenced him to reclusion perpetua without eligibility for parole, and ordered him to pay damages. The Court of Appeals affirmed the RTC’s decision but modified the amounts of damages awarded.

ISSUE

1. Whether the guilt of the accused-appellant for the crime charged was proven beyond reasonable doubt.
2. Whether the accused-appellant acted in self-defense.
3. Whether the crime committed was Murder or Homicide.

RULING

The Supreme Court denied the appeal and affirmed the modified decision of the Court of Appeals. The Court held that:
1. The prosecution proved the appellant’s guilt beyond reasonable doubt. The positive identification by eyewitnesses, whose testimonies were straightforward and consistent with the medical findings, prevailed over the appellant’s denial and self-defense claim. The elements of Murder were established: a person was killed; the accused killed him; the killing was attended by treachery; and the killing was not infanticide or parricide.
2. The plea of self-defense failed. By invoking self-defense, the appellant admitted the killing and assumed the burden to prove the justifying circumstance by clear and convincing evidence. The Court found the appellant’s version untenable. Even assuming unlawful aggression by the victim, it ceased once the appellant wrestled the knife away, and his subsequent act of inflicting multiple stab wounds demonstrated a resolved criminal intent, negating self-defense.
3. The crime committed was Murder qualified by treachery. The attack was sudden and unexpected, directed at an unarmed and unsuspecting victim who was seated and conversing, depriving him of any chance to defend himself. The penalty of reclusion perpetua was affirmed. The Court also affirmed the awards of ₱75,000.00 as civil indemnity, ₱75,000.00 as moral damages, and ₱30,000.00 as exemplary damages, with interest at 6% per annum from the finality of the resolution until fully paid.