G.R. No. 98196 , January 31, 1995
People of the Philippines vs. Eleuterio Adonis alias “Tandang”

FACTS

The accused-appellant, Eleuterio Adonis, was convicted of murder for the killing of Benedicto Basas. The prosecution’s evidence established that at around 7:00 p.m. on June 10, 1985, the victim was sitting on a bench in his front yard with his wife and son. Adonis suddenly appeared behind Basas and stabbed him once in the back with a “pisao,” causing his death. The accused then fled. The prosecution’s version was based on the eyewitness accounts of the victim’s wife and son.
Adonis invoked self-defense, claiming that while he and a companion were passing by the victim’s house, Basas, who was allegedly drunk and armed with a bolo, suddenly hacked at him. Adonis testified that he retaliated by stabbing Basas. He asserted that the victim had been challenging passersby to a fight. The trial court rejected this defense, found the killing attended by treachery, and convicted Adonis of murder, sentencing him to reclusion perpetua and ordering him to pay indemnity.

ISSUE

Whether the trial court erred in convicting the accused-appellant of murder and in rejecting his claim of self-defense.

RULING

The Supreme Court affirmed the conviction. The legal logic is anchored on the principle that one who invokes self-defense admits the killing and assumes the burden of proving its justifying circumstances by clear and convincing evidence. The accused must rely on the strength of his own evidence, not on the weakness of the prosecution’s case. Here, Adonis failed to discharge this burden.
The Court found the evidence for the defense insufficient to prove unlawful aggression, a requisite for self-defense. Critical testimonies were inconsistent. While Adonis and one witness initially claimed Basas was armed with a bolo, that same witness later recanted on cross-examination, stating he did not see a bolo. This directly undermined the claim of an armed attack. Other contradictions in the defense testimonies regarding the time of meeting and available routes further clouded the credibility of the defense witnesses. The defense’s attempt to prove the victim’s violent character through a barangay captain’s notebook and alleged specific acts was also correctly disregarded, as proof of character must pertain to general reputation, not isolated incidents, and the notebook lacked official character.
Conversely, the prosecution evidence clearly established treachery. The attack was sudden, from behind, against an unarmed and unsuspecting victim sitting peacefully in his yard. This method ensured the execution of the crime without risk to the assailant. The Court modified the award of civil indemnity from P30,000 to P50,000 in accordance with prevailing jurisprudence. The decision of the trial court was thus affirmed with this modification.