G.R. No. 236166, October 30, 2024
KENNETH KARL ASPIRAS Y CORPUZ, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioner Kenneth Karl Aspiras y Corpuz was charged with Murder for stabbing his common-law spouse, Jet Lee Reyes y Daquil, with a kitchen knife on January 13, 2011, in Manila. The Information alleged treachery, evident premeditation, and abuse of superior strength. After a preliminary investigation where probable cause was found, Aspiras pleaded not guilty. During trial, the prosecution presented witnesses, including the victim’s mother, Cleopatra Reyes, who testified that she overheard an argument between the couple before hearing Jet Lee scream that she had been stabbed by Aspiras. She saw Aspiras descending with bloodied hands and later assisted the wounded Jet Lee, who stated, “mommy sinaksak po ako ni Kenneth,” before dying at the hospital. Other witnesses testified to Aspiras’s jealous character and prior violent incidents. The medico-legal officer confirmed two stab wounds, one fatal. Aspiras claimed self-defense, alleging Jet Lee attacked him with the knife first, and they wrestled for it, resulting in her accidental stabbing. The Regional Trial Court convicted Aspiras of Homicide, not Murder, finding the qualifying circumstances not proven, and rejected his self-defense claim. The Court of Appeals affirmed the conviction with modification, adding an award of exemplary damages. Aspiras filed a Petition for Review, challenging the validity of the Information and his conviction.

ISSUE

1. Whether the Court of Appeals erred in not annulling the Regional Trial Court’s Decision for lack of jurisdiction due to an Information allegedly not signed and approved by the City Prosecutor as required under Rule 112, Section 4 of the Rules of Court.
2. Whether the Court of Appeals erred in affirming the petitioner’s conviction for Homicide.

RULING

The Petition is denied.
1. On the validity of the Information: The Court held that the Information was valid. While the Information was signed by an Assistant City Prosecutor, the records showed it was filed with the prior written authority of the City Prosecutor, as evidenced by a certification and the City Prosecutor’s approval of the preliminary investigation resolution finding probable cause. Any objection to the authority of the signing officer must be made via a motion to quash before entering a plea. By failing to do so and by actively participating in the trial, Aspiras is deemed to have waived any such defect.
2. On the conviction for Homicide: The Court affirmed the conviction. The trial court’s factual findings, affirmed by the Court of Appeals, are binding. Aspiras failed to prove the elements of self-defense by clear and convincing evidence. His version of events was found sketchy and inconsistent. The prosecution evidence established that Aspiras stabbed Jet Lee, causing her death, without the qualifying circumstances of Murder. Thus, his conviction for the lesser crime of Homicide stands. The awards of civil indemnity, moral damages, and exemplary damages, with interest, are upheld.