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

FACTS

Accused-appellant Juan Dela Cruz was charged with the crime of Murder for the fatal stabbing of Pedro Santos. The prosecution presented eyewitness testimony and forensic evidence. The defense interposed self-defense, claiming that Santos was the unlawful aggressor who attacked him with a knife during a sudden quarrel. The Regional Trial Court convicted Dela Cruz of Murder, qualified by treachery, and sentenced him to *reclusion perpetua*. The Court of Appeals affirmed the conviction. Dela Cruz appealed to the Supreme Court, arguing that the lower courts erred in not appreciating self-defense and in finding the presence of treachery.

ISSUE

Whether the Court of Appeals erred in:
1. Not appreciating the justifying circumstance of self-defense; and
2. Finding that the killing was attended by treachery.

RULING

1. On the claim of self-defense: NO. The appeal is without merit. In criminal law, one who invokes self-defense admits the killing and bears the burden of proving by clear and convincing evidence the concurrence of its essential elements: (a) unlawful aggression on the part of the victim; (b) reasonable necessity of the means employed to prevent or repel it; and (c) lack of sufficient provocation on the part of the person defending himself. Here, accused-appellant failed to prove unlawful aggression. His testimony was inconsistent and uncorroborated. The nature, location, and number of the victim’s woundsmultiple stab wounds on the backare physical facts incompatible with a claim of self-defense against a frontal attack. The physical evidence conclusively belies his narrative.

2. On the qualifying circumstance of treachery: NO. The appeal is likewise without merit. Treachery (*alevosia*) exists when the offender employs means, methods, or forms in the execution of the crime which tend directly and specially to ensure its execution, without risk to himself arising from the defense which the offended party might make. The prosecution evidence established that the victim was attacked from behind while walking away, rendering him unable to defend himself or retaliate. The mode of attack was deliberate and unexpected, ensuring the execution of the killing without any risk to the accused. The qualifying circumstance of treachery was correctly appreciated.

WHEREFORE, the Court AFFIRMS the Decision of the Court of Appeals in toto. Costs against accused-appellant.