GR L 21417; (January, 1966) (Digest)
G.R. No. L-21417 January 31, 1966
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NICOLAS QUINTAB, defendant-appellant.
FACTS
The accused-appellant, Nicolas Quintab, a prisoner and trusty in the provincial jail of Bacolod City, was convicted of murder and sentenced to life imprisonment for the stabbing death of Jesus Navarra inside the jail on July 5, 1962. The prosecution’s eyewitness, Wilfredo Berja, testified that he and Navarra were visiting detainees when Quintab suddenly stabbed Navarra from behind at the nape, then turned him around and stabbed him a second time in the breast. Quintab’s co-accused, Romeo Prado and Romeo Diapante, armed with knives, blocked Berja from pursuing Quintab. The autopsy confirmed two stab wounds, with the chest wound being fatal. Quintab admitted the killing but claimed self-defense, alleging that Navarra initiated a fistfight and that the knife either fell from Navarra’s pocket or was thrown by Berja. He surrendered the knife to the acting provincial warden afterward.
ISSUE
The central issue involves the credibility of the conflicting accounts and whether the accused-appellant successfully proved that the killing was legally justifiable, such as in self-defense.
RULING
The Supreme Court affirmed the conviction. The burden of proving justification for the killing lay with the appellant, and he failed to meet this burden. The trial court correctly gave greater weight to the testimony of the neutral prosecution witness, Wilfredo Berja, whose account was more consistent with probabilities. Appellant’s claim about the origin of the knife contradicted prison regulations prohibiting visitors from bringing weapons inside. Discrepancies between his sworn statement and court testimony further undermined his credibility. The evidence indicated the killing was planned, as shown by the armed co-accused blocking pursuit. The crime was murder qualified by evident premeditation and aggravated by treachery, but the latter was offset by voluntary surrender. The penalty of life imprisonment was correctly imposed.