G.R. No. 123456, *People of the Philippines v. Juan Dela Cruz*, January 15, 2020

FACTS:
Accused-appellant Juan Dela Cruz was charged with the crime of Murder for the fatal stabbing of Pedro Santos. The prosecution presented eyewitness Maria Reyes, who testified that she saw Dela Cruz, without any provocation, stab Santos multiple times. The defense interposed self-defense, claiming that Santos was the initial aggressor who attacked Dela Cruz with a bladed weapon. The Regional Trial Court convicted Dela Cruz of Murder, appreciating the qualifying circumstance of treachery. The Court of Appeals affirmed the conviction.

ISSUE

Whether the accused-appellant is guilty of Murder, or whether his claim of self-defense is valid.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of the accused-appellant for the crime of MURDER, qualified by treachery.

The Court held that when an accused invokes self-defense, the burden of proof shifts to him to establish the elements thereof by clear and convincing evidence. Here, Dela Cruz failed to discharge this burden. His testimony was riddled with inconsistencies and was not corroborated by objective evidence. In contrast, the testimony of the prosecution eyewitness was credible, straightforward, and consistent with the physical evidence. The Court found that the attack was sudden and unexpected, depriving the victim of any opportunity to defend himself, thereby satisfying the elements of treachery which qualified the killing to Murder. The mitigating circumstance of voluntary surrender was appreciated in his favor. The penalty was imposed accordingly, with modifications to the awarded damages.