G.R. No. 242263 , November 18, 2020
Aron Anisco, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner Aron Anisco and his brother Franklin were charged with Homicide for the death of Rolly Apinan during a New Year’s celebration. The prosecution, through the testimonies of the victim’s wife and brother, established that Franklin pointed a gun at Rolly on a stage, stepped back, and fired, hitting Rolly in the chest. Aron was present on the stage, having just greeted the victim. Both accused fled the scene together. The victim died from the gunshot wound. Aron later surrendered and allegedly admitted involvement.
Aron, however, invoked self-defense. He testified that Rolly was the initial aggressor who pulled out a gun. Aron claimed he grappled with Rolly for possession of the weapon, during which it accidentally fired, killing Rolly. The Regional Trial Court (RTC) acquitted Franklin for lack of evidence but convicted Aron of Homicide, rejecting his claim of self-defense. The Court of Appeals affirmed the conviction.

ISSUE

Whether the Court of Appeals erred in affirming Aron Anisco’s conviction for Homicide by rejecting his claim of self-defense.

RULING

The Supreme Court denied the petition and affirmed the conviction. The legal logic rests on the settled principle that self-defense is an affirmative allegation, and the burden of proof rests upon the accused to prove its elements by clear and convincing evidence. These elements are: (1) unlawful aggression by the victim; (2) reasonable necessity of the means employed to prevent or repel it; and (3) lack of sufficient provocation on the part of the person defending himself.
The Court found that Aron failed to discharge this burden. His testimony that the gun fired accidentally during a struggle negated the essential element of reasonable necessity of the means employed, as an accidental shooting is incompatible with a deliberate act of defense. Furthermore, the trial court’s assessment of witness credibility, which favored the consistent and categorical testimonies of the prosecution eyewitnesses over the defense’s version, is accorded great weight and respect on appeal. The factual findings of the RTC, affirmed by the CA, are conclusive absent any showing of arbitrariness. Consequently, the prosecution successfully proved Aron’s guilt beyond reasonable doubt. The Court modified the awarded damages, increasing civil indemnity, moral damages, and exemplary damages to Seventy-Five Thousand Pesos (₱75,000.00) each, all with legal interest.