G.R. No. 245969 , November 03, 2020
People of the Philippines, Plaintiff-Appellee, vs. Joel Catulang y Gutierrez, Poly Bertulfo y Delloro, and Crispolo Bertulfo y Delloro, Accused-Appellants.

FACTS

The case stemmed from the killing of Romeo Cantiaga on September 7, 2008, in Caloocan City. The prosecution, primarily through the testimony of the victim’s wife, Lydia, alleged that accused-appellants, together with Manuel Catulang, conspired to attack Romeo. Lydia testified that Manuel initially struck Romeo with a piece of wood, after which appellants Joel, Poly, and Crispolo dragged the victim inside a house compound. She claimed to have seen through the gate the four men mauling and stabbing Romeo with a bolo and screwdriver. The autopsy confirmed multiple stab wounds and injuries consistent with a violent assault.
The defense presented a different narrative, claiming self-defense and defense of a relative. They asserted that Romeo and his son, Raffy, were the initial aggressors, attacking Manuel’s house with stones and attempting to force entry while armed. The appellants contended they acted only to repel this unlawful aggression, with Crispolo testifying he stabbed Romeo only after the victim charged at him with a knife inside the house. The Regional Trial Court convicted all accused of Murder, a decision affirmed by the Court of Appeals.

ISSUE

Whether the guilt of accused-appellants for the crime of Murder was proven beyond reasonable doubt.

RULING

The Supreme Court ACQUITTED Joel Catulang but AFFIRMED the conviction of Poly and Crispolo Bertulfo for Murder. The Court applied the constitutional presumption of innocence and the standard of proof beyond reasonable doubt. For Joel Catulang, the evidence failed to meet this standard. The prosecution’s sole eyewitness, Lydia, gave inconsistent testimonies regarding Joel’s specific participation, initially stating he was armed with wood and later failing to consistently identify his role in the stabbing. Her testimony was also contradicted by another witness on key details. These inconsistencies created reasonable doubt as to Joel’s criminal liability.
However, for Poly and Crispolo Bertulfo, the defense of self-defense and defense of a relative was unjustified. The Court ruled that the elements of self-defense were not established. The appellants failed to prove unlawful aggression on the part of the victim at the precise moment of the lethal act. The medical evidence showed the victim sustained three fatal stab wounds in the thorax and multiple other injuries, indicating a determined attack rather than a purely defensive response. The nature, number, and location of the wounds were incompatible with the claimed defense and demonstrated a clear intent to kill. Thus, their guilt for Murder was proven beyond reasonable doubt. The Court modified the damages awarded, increasing exemplary damages and awarding temperate damages in lieu of actual damages.