GR No. 123456, January 30, 2024
People of the Philippines v. Juan Dela Cruz

FACTS

The accused, Juan Dela Cruz, was charged with the crime of Robbery with Homicide. The prosecution presented evidence that Dela Cruz entered the victim’s home, stole various valuables, and, upon being discovered by the homeowner, stabbed the latter, causing his death. The defense interposed the justifying circumstance of self-defense, claiming that the homeowner allegedly attacked him first with a bladed weapon, and he merely acted to protect himself. The Regional Trial Court (RTC) convicted Dela Cruz, finding that the evidence for self-defense was unconvincing and failed to prove the elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The Court of Appeals affirmed the RTC’s decision. Dela Cruz now appeals to the Supreme Court via a petition for review on certiorari, reiterating his claim of self-defense.

ISSUE

Whether or not the Court of Appeals erred in affirming the conviction of the accused, despite his claim of self-defense.

RULING

No, the Court of Appeals did not err.

The Supreme Court denied the petition and affirmed the decisions of the lower courts. The Court reiterated the well-settled doctrine that when an accused invokes self-defense, the burden of proof shifts to him to establish by clear and convincing evidence the concurrence of all its essential elements: (1) unlawful aggression on the part of the victim; (2) reasonable necessity of the means employed to prevent or repel it; and (3) lack of sufficient provocation on the part of the person defending himself. Of these, unlawful aggression is the indispensable element. Without it, there can be no valid claim of self-defense.

In this case, the Court found that the accused failed to discharge this burden. His testimony was deemed inconsistent and uncorroborated. The nature, location, and number of the fatal wounds inflicted on the victim were not commensurate with a mere act of repelling an attack but indicated a determined effort to kill. Furthermore, the accused’s flight from the scene and his failure to report the incident to authorities immediately were contrary to the behavior of one who acted in lawful self-defense. The factual findings of the trial court, affirmed by the Court of Appeals, are generally binding on the Supreme Court, especially on matters of witness credibility. There being no showing that the lower courts overlooked or misappreciated facts of substance, the conviction must stand. The crime of Robbery with Homicide under Article 294 of the Revised Penal Code was duly proven beyond reasonable doubt.