GR 232247; (April, 2018) (Digest)
G.R. No. 232247. APRIL 23, 2018.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RONILLO LOPEZ, JR. y MANTALABA @ “DODONG”, Accused-Appellant.
FACTS
The prosecution established that in the early morning of May 16, 2014, in Las Piñas City, accused-appellant Ronillo Lopez, Jr. sought help from his grandmother, Martita Lopez, shouting that he had stabbed his father. Martita and another witness proceeded to the scene and found the victim, Ronillo Lopez, Sr., dead from a stab wound. Appellant fled but was later arrested. The defense, while admitting the fatal stabbing, interposed self-defense. Appellant claimed he was asleep at home when his drunken father suddenly attacked and beat him, urging him to fight back. He alleged his father struck his head with a hard object, causing him to lose control (“Nagdilim ang aking paningin”) and retaliate with a knife.
ISSUE
Whether the Court of Appeals correctly affirmed the trial court’s finding that accused-appellant is guilty of Parricide, rejecting his claim of self-defense.
RULING
The Supreme Court affirmed the conviction. The legal logic is anchored on the requisites of self-defense. When an accused admits the killing and invokes self-defense, the burden of proof shifts to him to establish by clear and convincing evidence the elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The Court found appellant’s claim of unlawful aggression unsupported by credible evidence. His testimony was uncorroborated and deemed inherently doubtful. The physical evidence, particularly the victim’s multiple injuries, did not conclusively prove the victim was the aggressor. The Court emphasized that self-defense cannot be sustained where unlawful aggression is not proven; the mere plea of having “lost control” does not constitute a legal defense. The crime was properly qualified as Parricide under Article 246 of the Revised Penal Code, as the victim was the appellant’s father. The penalty of Reclusion Perpetua was correctly imposed. The Court also sustained the modified awards of damages in line with prevailing jurisprudence.