GR L 17243; (August, 1966) (Digest)
G.R. No. L-17243 August 23, 1966
THE PEOPLE OF THE PHILIPPINES, plaintiff and appellee, vs. IGNACIO VILLALBA, defendant and appellant.
FACTS
On November 16, 1956, Ignacio Villalba hit and lamed a pig owned by Ignacio Cabanada after it ate some of his chicks. The barrio lieutenant investigated, and Villalba admitted the act. Cabanada demanded P20, but Villalba offered P10 and requested ten days to pay. Cabanada left unceremoniously.
The following evening, November 17, 1956, a group including Cabanada was walking home after playing a game. According to prosecution witnesses Pablo Bengzon, Florentino Labrador, and Alfredo Cachuela, Villalba suddenly emerged from tall palay stalks along their path, went behind Cabanada, and struck him with a bolo on the right forehead and left elbow. Cabanada died the next day from his injuries.
Villalba claimed self-defense, testifying that Cabanada, Bengzon, and Cachuela waylaid him with bolos and a cane as he returned from visiting his sick father. He alleged he picked up a bolo that touched his hip and swung it, hitting Cabanada only after Cabanada lunged at him with a dagger.
An information for murder was filed against Villalba. After trial, the Court of First Instance found him guilty of murder qualified by treachery and sentenced him to reclusion perpetua, indemnity, and costs. Villalba appealed.
ISSUE
Whether the trial court erred in convicting Ignacio Villalba of murder, rejecting his claim of self-defense and finding the killing attended by treachery.
RULING
The Supreme Court affirmed the conviction. The trial court’s findings on the credibility of witnesses are entitled to respect, and no fact of substance was overlooked. The positive and clear eyewitness accounts of three witnesses (one for the prosecution and two for the defense) established Villalba’s guilt. Their testimony showed that Villalba suddenly emerged from concealment and immediately hacked the deceased, constituting a sudden and unexpected attack that qualifies the killing as murder with treachery. The claim of lack of motive is unavailing, as motive is unessential when the identity of the culprit is certain, and there was a prior altercation over the pig incident. The defense’s reliance on hearsay letters from the deceased’s wife, which prompted a provisional dismissal of an earlier information, cannot prevail over the direct eyewitness testimony. The judgment was affirmed.