G.R. No. 227502 , JULY 23, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. RANDY GAJILA y SALAZAR, Accused-Appellant

FACTS

The prosecution established that on January 24, 2008, at the Quinta Market in Manila, accused-appellant Randy Gajila, appearing drunk, approached the victim, Gerry Alcantara, from behind while the latter was busy weighing meat. Without warning, Gajila held the victim by the neck and stabbed him twice in the back with a butcher’s knife. The attack was interrupted by a witness who intervened, after which Gajila fled but was later apprehended. The victim succumbed to his wounds the following day. The autopsy report confirmed the cause of death was a stab wound at the back.
In his defense, Gajila claimed self-defense. He testified that the victim suddenly approached him, uttered words, and boxed him multiple times. He alleged that during a struggle where the victim was on top of him, he picked up a knife that had fallen from the victim’s waist and stabbed him only once, without intent to kill. He presented a medical certificate showing no external injuries on his person.

ISSUE

The core issue is whether the accused-appellant successfully proved the justifying circumstance of self-defense to exculpate himself from criminal liability for murder.

RULING

The Supreme Court affirmed the conviction for murder, ruling that the accused-appellant failed to prove self-defense by clear and convincing evidence. When an accused invokes self-defense, the burden of proof shifts to him to establish its elements: unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The Court found Gajila’s claim of unlawful aggression by the victim unconvincing. His medical certificate showing no injuries contradicted his testimony of having been boxed multiple times and pressed on the neck. Furthermore, his claim of stabbing the victim only once was directly refuted by the autopsy report showing two stab wounds.
The Court upheld the finding of treachery (alevosia) as a qualifying circumstance, which elevated the killing to murder. The attack was sudden, from behind, and employed a deadly weapon against an unarmed victim who was preoccupied with his work, giving him no opportunity to defend himself. This method of execution deliberately ensured the execution of the crime without risk to the assailant. The Court modified the damages awarded, increasing exemplary damages to Seventy-Five Thousand Pesos (₱75,000.00) in line with prevailing jurisprudence. The penalty of reclusion perpetua was affirmed.