G.R. No. L-13294. March 29, 1961.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ISIDORO ESCALONA and EPIFANIO ESCALONA, defendants-appellants.

FACTS

On the evening of April 6, 1957, Protacio Eval, his mother Felicidad, and sister Patricia were walking home from a prayer meeting in Tacloban City. They passed by a group of four men, including appellants Isidoro and Epifanio Escalona. After walking about 18 meters away, Isidoro suddenly attacked Protacio from behind, embracing him and stabbing his left forearm with a hunting knife. Felicidad intervened and was wounded. While Isidoro held Protacio, Epifanio approached and stabbed Protacio in the back. Assistant barrio lieutenant Antonio Encomia responded to cries for help, witnessing the struggle and seeing Epifanio holding a knife nearby. The victim was taken to the hospital but died four days later from his wounds, which included a fatal penetrating chest wound.
The appellants presented contrasting defenses. Isidoro claimed self-defense, alleging that Protacio had attacked him first with a bolo after a refused drinking invitation, forcing him to retaliate. Epifanio denied any involvement, asserting he was merely a passerby who assisted Encomia in disarming Isidoro and was later instructed to report the incident to authorities.

ISSUE

Whether the trial court correctly convicted the appellants of the crime of murder.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court found the testimonies of the prosecution witnesses, particularly Felicidad Eval and Antonio Encomia, to be credible and consistent on material points. Their accounts established that Isidoro initiated a sudden attack from behind, and Epifanio delivered the fatal stab while the victim was restrained. This manner of attack constituted treachery (alevosia), qualifying the killing as murder under Article 248 of the Revised Penal Code.
Isidoro’s claim of self-defense was untenable. The nature and location of the victim’s wounds—particularly the back stab—contradicted his narrative of a mutual bolo fight. The Court noted that the appellants had been drinking earlier, which may have contributed to the senseless violence, even absent a clear motive. Epifanio’s denial of complicity was rejected, as the evidence positively placed him at the scene, actively participating by delivering the fatal blow. The Court held that the qualifying circumstance of treachery absorbed the aggravating circumstance of superior strength. Nighttime was not considered aggravating as it was not purposely sought. No mitigating circumstances were present. Consequently, the penalty was imposed in its medium period, which is reclusion perpetua, modifying the trial court’s imposition of the death penalty. The rest of the judgment, including the indemnity, was affirmed.