GR 219848; (June, 2017) (Digest)
G.R. No. 219848, June 7, 2017
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. GODOFREDO MACARAIG y GONZALES, Accused-Appellant
FACTS
The prosecution established that in the early morning of May 31, 2011, in Calabanga, Camarines Sur, accused-appellant Godofredo Macaraig followed the victim, Joven Celeste, as he was walking home from a dance party. Prosecution eyewitness Francis Losano saw Macaraig approach Joven from behind, place an arm over his shoulder, and suddenly stab him. Joven managed to return home, identified Macaraig as his assailant to his cousin while being transported to the hospital, but was declared dead on arrival from a single, fatal stab wound. The defense presented Macaraig as its sole witness, who claimed self-defense. He alleged that on the same night, two unidentified men attacked him with a balisong and a bolo, and it was one of these men who was accidentally stabbed during the struggle, not Joven.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s conviction of the accused-appellant for Murder, and in rejecting his plea of self-defense.
RULING
The Supreme Court dismissed the appeal and affirmed the conviction for Murder, with modifications to the awarded damages. The Court meticulously applied the legal principles governing self-defense. It reiterated that self-defense is an affirmative allegation; an accused who admits the killing assumes the burden of proving by clear and convincing evidence the concurrence of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The Court found that Macaraig utterly failed to discharge this burden. His testimony was deemed uncorroborated and inconsistent with the physical evidence and the credible, positive identification by the prosecution eyewitness. Crucially, he could not prove the indispensable element of unlawful aggression initiated by the victim. The attack from behind, as described by the eyewitness, constituted treachery (alevosia), which qualified the killing to Murder. The penalty of reclusion perpetua, without eligibility for parole, was affirmed. The Court modified the damages, increasing moral and exemplary damages to Seventy-Five Thousand Pesos (PhP75,000.00) each, in line with prevailing jurisprudence, with all amounts subject to legal interest.