G.R. No. 39799; March 20, 1934
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. PEDRO NARVAES, defendant-appellant.

FACTS

The appellant, Pedro Narvaes, was convicted of homicide for stabbing and killing Benito de Silva, his foreman, on August 28, 1932, in Cabuyao, Laguna. The prosecution evidence established that after being rebuked by de Silva for not joining the plowing work promptly, Narvaes later confronted and attacked de Silva with a penknife, inflicting three fatal wounds. Narvaes claimed self-defense, alleging that de Silva had insulted him, choked him, thrown him to the ground, and mounted him, forcing him to use his penknife. The trial court rejected this defense, finding Narvaes to be the aggressor, and sentenced him to reclusion temporal.

ISSUE

1. Whether the appellant acted in self-defense.
2. Whether the ante-mortem declaration of the deceased was admissible.
3. Whether the appellant’s true name is Primo Narvaes, not Pedro Narvaes.
4. Whether the trial court erred in convicting and sentencing the appellant.

RULING

1. No, self-defense was not established. The Supreme Court found the prosecution evidence more credible, showing the appellant was the aggressor. The appellant’s own statement to the police indicated he attacked due to insulting remarks. The court rejected the defense witnesses’ testimony as improbable and inconsistent.
2. The admissibility of the ante-mortem declaration was not a reversible error. The court did not find it necessary to rule definitively on this issue as the conviction was sufficiently supported by other evidence.
3. The appellant is correctly identified as Pedro Narvaes. The evidence, including tenant census records and the appellant’s failure to raise the issue of identity during arraignment, established his identity as Pedro Narvaes. He is estopped from disputing it on appeal.
4. The trial court did not err in convicting the appellant of homicide. The act constituted homicide under Article 249 of the Revised Penal Code. With no aggravating or mitigating circumstances, the penalty was properly imposed in the medium period of reclusion temporal.

The appealed judgment was affirmed, but pursuant to the Indeterminate Sentence Law (Act No. 4103) and considering the appellant’s youth (19 years old at the time of the crime), the Supreme Court modified the sentence to an indeterminate penalty of six years and one day of prision mayor as minimum, to fourteen years, eight months, and one day of reclusion temporal as maximum.

AI Generated by Armztrong.