G.R. No. 233085 . September 21, 2020.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ARMANDO ARCHIVIDO Y ABENGOZA, ACCUSED-APPELLANT.

FACTS

Accused-appellant Armando Archivido was charged with Murder for the killing of his sister-in-law, Lilia Archivido, and Frustrated Murder for the attack on his brother, Ruben Archivido. The prosecution established that on July 31, 2009, a long-standing land dispute between the brothers culminated in a violent encounter. While Ruben and Lilia were walking home, Armando intentionally bumped Lilia, leading to an argument. After a brief reconciliation, Armando suddenly hacked Lilia from behind with a bolo. When Ruben rushed to aid his wife, Armando also attacked him, inflicting multiple hacking wounds. Lilia died from her injuries, while Ruben survived after extensive medical treatment.
Armando admitted the killings but interposed the justifying circumstance of self-defense. He claimed that Lilia first threatened him regarding a separate case, and that both victims, armed with bolos, attacked him first. He alleged he only fought back to defend himself, subsequently surrendering at the police station. The Regional Trial Court convicted Armando of both charges, rejecting his defense. The Court of Appeals affirmed the RTC’s decision.

ISSUE

Whether the Court of Appeals erred in affirming Armando Archivido’s conviction for Murder and Frustrated Murder.

RULING

The Supreme Court denied the appeal and affirmed the convictions. The Court meticulously applied the settled rule that when an accused admits the act but pleads self-defense, the burden of proof shifts to him to establish the justifying circumstance by clear and convincing evidence. Armando failed to discharge this burden. His version of events was deemed inherently improbable and inconsistent with the physical evidence. The nature, number, and location of the victims’ wounds—particularly the fatal hack on Lilia from behind—contradicted his claim of a sudden, mutual armed aggression. The Court found the prosecution’s narrative, corroborated by Ruben’s credible testimony and medical findings, to be more consistent with a deliberate and unprovoked attack.
Furthermore, the Court affirmed the qualifying circumstance of treachery (alevosia) for the Murder charge. The attack on Lilia was sudden and from behind, ensuring she had no opportunity to defend herself. For the Frustrated Murder charge, the Court upheld the finding that Armando performed all acts of execution intended to kill Ruben, and that Ruben’s survival was due solely to timely medical intervention independent of Armando’s will. The awards of damages were modified in accordance with prevailing jurisprudence. The plea of voluntary surrender was correctly denied for lack of factual basis.