G.R. No. 217974, March 5, 2018
People of the Philippines, Plaintiff-Appellee vs. Resurrecion Juanillo Manzano, Jr. and Rezor Juanillo Manzano, Accused; Rezor Juanillo Manzano, Accused-Appellant.

FACTS

Accused-appellant Rezor Juanillo Manzano and his brother were charged with Murder for stabbing Lucio Silava. The prosecution’s version, presented through the victim’s wife Victoria, stated that on March 19, 2010, the Manzano brothers entered the Silavas’ store under the pretense of buying cigarettes. Rezor proceeded to the kitchen where Lucio was eating, and Victoria soon heard Lucio ask, “What wrong have I committed?” She then saw both brothers stabbing Lucio. Victoria witnessed Resurrecion holding Lucio’s hands while Rezor, positioned behind, stabbed his back. The postmortem examination revealed six stab wounds, including fatal injuries to the lungs, aorta, and liver.
The defense presented an inverted trial after Rezor pleaded not guilty and claimed self-defense. Rezor testified that he was at home when he saw Lucio throwing stones at his house. When he confronted him, Lucio threw a stone that hit his knee, causing him to fall. Lucio then allegedly tried to stab him, leading to a struggle over the knife. Rezor claimed he was able to take the knife, blacked out, and stabbed Lucio. He then surrendered to police the following day.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s finding of guilt for Murder, and whether accused-appellant’s claim of self-defense is credible.

RULING

The Supreme Court denied the appeal but modified the conviction from Murder to Homicide. The Court found that the prosecution successfully established that Rezor inflicted fatal wounds upon Lucio, thereby overcoming the presumption of innocence. However, the qualifying circumstances of treachery and abuse of superior strength were not proven beyond reasonable doubt. The medical findings of multiple stab wounds, some inflicted from behind, did not by themselves establish treachery, as the prosecution failed to clearly prove how the attack was commenced in a manner that ensured the victim’s defenselessness. The claim of abuse of superior strength was also not sufficiently established, as the evidence did not clearly show that the brothers cooperated to secure an advantage in strength.
Regarding self-defense, the Court ruled that Rezor failed to prove its essential elements by clear and convincing evidence. The nature, number, and location of the victim’s wounds—six stab wounds, including fatal injuries to vital organs—were inconsistent with a spontaneous, instinctive act of defense and instead indicated a determined effort to kill. The claim of blacking out was deemed insufficient to absolve criminal liability. Consequently, while criminal liability was affirmed, the absence of qualifying circumstances warranted the conviction for the lesser crime of Homicide under Article 249 of the Revised Penal Code. The Court imposed an indeterminate penalty and ordered the accused-appellant to pay civil indemnity, moral damages, and temperate damages to the victim’s heirs.