G.R. No. 245306 , December 02, 2020
People of the Philippines, Plaintiff-Appellee, vs. Edgar Guarin y Veloso a.k.a. “Banong,” Accused-Appellant.

FACTS

Accused-appellant Edgar Guarin was charged with Murder for the killing of Manny Manaois. The prosecution’s eyewitness, Arcadio Botial, testified that on May 27, 2016, while he and the unarmed victim were preparing for work, Guarin suddenly and without provocation stabbed Manaois multiple times as the victim was about to board his tricycle. Botial stated that Guarin pursued the fleeing victim to continue the attack. Barangay Kagawad Arnold Rosario later found Guarin sitting on the floor holding a bloodied knife. The victim sustained twelve stab wounds and died on the same day.
Guarin claimed self-defense, alleging that the victim, who appeared drunk and armed with a knife, initiated the attack by attempting to stab him twice. Guarin asserted that he was able to disarm the victim but did not know what transpired afterward, only realizing he may have harmed Manaois when he saw blood on himself. He then surrendered to the barangay official. The trial court found his testimony unconvincing and convicted him of Murder.

ISSUE

Whether the Court of Appeals correctly affirmed the trial court’s conviction of the accused for the crime of Murder.

RULING

Yes, the conviction is affirmed. The Supreme Court upheld the findings of the lower courts, giving great weight to the consistent and credible testimony of the prosecution eyewitness over the accused’s claim of self-defense. For self-defense to exculpate an accused, the elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation must be proven by clear and convincing evidence. The Court found that Guarin failed to establish unlawful aggression on the part of the victim. The sudden and treacherous nature of the attack, as described by the eyewitness who saw the unarmed and unsuspecting victim being stabbed, negated the existence of any imminent threat from the victim to the accused. The number, location, and severity of the twelve stab wounds further demonstrated a determined intent to kill, disproving the reasonable necessity of the means employed for defense. The claim of surrender was acknowledged but deemed inconsequential to the justification of the killing, serving only to mitigate civil liability. The qualifying circumstance of treachery was properly appreciated as the attack was deliberate, sudden, and rendered the victim unable to defend himself. The penalty of reclusion perpetua and the awarded damages were affirmed.