G.R. No. 210975 , March 11, 2020
PO1 Apolinario Bayle y Junio, Petitioner, v. People of the Philippines, Respondent.

FACTS

Petitioner PO1 Apolinario Bayle was charged with Homicide for killing Lorico Lampa and Frustrated Homicide for shooting Crisanto Lozano on October 17, 2004, in Makati City. The prosecution’s version, based on witnesses Crisanto Lozano and Ricardo Lampa (Lorico’s father), was that an altercation occurred between Lorico and Apolinario outside the latter’s residence. Apolinario went up his house, returned with a gun, and while on the stairs, shot Crisanto in the back as he fled, and then shot Lorico in the chest. Lorico died, while Crisanto survived after medical treatment. The defense, invoking self-defense and defense of a relative, claimed that during a party at the Lampa compound, Lorico shouted threats at Apolinario’s apartment. Later, Crisanto and another person, both armed with bladed weapons, forcibly entered the apartment, attacked Apolinario’s wife (who was pregnant), and struggled with Apolinario. Apolinario was able to get his gun and shot Crisanto to protect his wife. Immediately after, Lorico, armed with a knife, charged at them, prompting Apolinario to shoot him. The Regional Trial Court found Apolinario guilty, a decision affirmed by the Court of Appeals.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s judgment finding petitioner Apolinario Bayle guilty beyond reasonable doubt of Homicide and Frustrated Homicide.

RULING

The Supreme Court DENIED the petition and AFFIRMED the assailed Court of Appeals Decision. The Court held that the petitioner failed to prove the justifying circumstances of self-defense and defense of a relative by clear and convincing evidence. When an accused invokes self-defense, the burden of proof shifts to them to establish its elements (unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation) by clear and convincing evidence. The Court found the petitioner’s version of events improbable and inconsistent with the physical evidence. The trajectory of the bullet that killed Lorico indicated the shooter was at a higher position, supporting the prosecution’s claim that the shooting occurred while Apolinario was on the stairs, not inside his apartment as he claimed. Furthermore, the nature and location of Crisanto’s wounds (a gunshot at the back and a separate lacerated wound) contradicted the claim of a close-quarters struggle inside the apartment. The positive and categorical testimonies of the prosecution witnesses were found more credible than the defense’s account. The Court also ruled that the justifying circumstance of defense of a relative could not be appreciated as the unlawful aggression had already ceased when the fatal shots were fired. Thus, the petitioner’s guilt for Homicide and Frustrated Homicide was proven beyond reasonable doubt.