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 eyewitnesses who testified to seeing Dela Cruz attack the unarmed victim from behind. The defense interposed self-defense, claiming that Santos had first attacked Dela Cruz with a knife. The Regional Trial Court (RTC) convicted Dela Cruz of Murder, finding the elements of treachery (alevosia) present. The Court of Appeals (CA) affirmed the RTC decision in toto. Dela Cruz now appeals before the Supreme Court, arguing that the lower courts erred in appreciating treachery and in not giving credence to his claim of self-defense.

ISSUE

Whether or not the accused-appellant is guilty of Murder, qualified by treachery, or a lesser offense.

RULING

The Supreme Court PARTIALLY GRANTED the appeal. The conviction is MODIFIED. Accused-appellant Juan Dela Cruz is found guilty of Homicide, not Murder, and is sentenced to an indeterminate penalty of six (6) years and one (1) day of *prision mayor* as minimum, to fourteen (14) years, eight (8) months and one (1) day of *reclusion temporal* as maximum.

The Court held that while the killing was proven beyond reasonable doubt, the qualifying circumstance of treachery was not sufficiently established. For treachery to qualify a killing as Murder, two conditions must concur: (1) the employment of means of execution that gives the person attacked no opportunity to defend himself or retaliate; and (2) the means of execution was deliberately or consciously adopted. The prosecution evidence failed to show with clarity how the assault commenced. The eyewitness account only began at the point where the victim was already being stabbed, leaving the initial attack unexplained. Without proof of the manner by which the attack was initiated, the essence of treacherythe deliberate adoption of a method to ensure the execution of the crime without risk to the aggressorcannot be presumed. Doubts must be resolved in favor of the accused. Consequently, the crime is Homicide under Article 249 of the Revised Penal Code.

Furthermore, the claim of self-defense was correctly rejected by the lower courts. The burden of proof shifts to the accused when self-defense is invoked. Dela Cruz failed to prove by clear and convincing evidence the elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. His testimony was inconsistent and uncorroborated. The physical evidence, particularly the location and number of wounds on the unarmed victim, belied his claim.