G.R. No. 94529 May 8, 1990
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RICARDO REYES, accused-appellant.

FACTS

On the afternoon of May 12, 1988, police aide Clotildo Micayabas was walking along Colon Street in Dumaguete City, with another police aide, Porferio Generoso, about five arms length behind him. Accused-appellant Ricardo Reyes suddenly stabbed Micayabas with an eleven-inch stainless knife, inflicting a stab wound on the right chest which caused massive bleeding and death. Reyes immediately fled and hid in Valencia, Negros Oriental, where he was arrested six days later. At trial, Reyes claimed self-defense, alleging that Micayabas approached him at his market table, pushed him, and aimed a pistol at him, saying, “This is your end, Bay,” prompting him to instinctively parry the pistol and stab Micayabas with a knife. The prosecution presented evidence that police aides were not issued firearms, and eyewitness Generoso testified that Micayabas was unarmed and that Reyes had hidden behind a cluster of small stores, darted out, and stabbed Micayabas, ensuring his own safety and giving the victim no chance to defend himself. A motive was established from Reyes’s admission that Micayabas had previously pulled his vegetable winnower while he was selling in the market.

ISSUE

Whether the accused-appellant’s claim of self-defense is valid to exculpate him from the crime of Murder.

RULING

No. The Supreme Court affirmed the Regional Trial Court’s decision finding accused-appellant Ricardo Reyes guilty of Murder, with modification increasing the indemnity. The Court found that the essential element of unlawful aggression on the part of the victim required for self-defense was absent. The evidence showed that the victim, a police aide, was not issued a firearm and was weaponless when attacked. Instead, the accused-appellant hid, waited for the victim, and suddenly attacked him with a knife, ensuring the victim could not retaliate. This manner of attack constituted the qualifying circumstance of alevosia (treachery). Consequently, the guilt of the accused-appellant for the crime of Murder was established beyond reasonable doubt. The penalty of reclusion perpetua was affirmed, and the civil indemnity was increased to P50,000.00.