G.R. No. L-30302 August 14, 1974
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SERGIO MALIWANAG, JESUS VILLEZA, and EULOGIO JALOS, defendants, JESUS VILLEZA, defendant-appellant.

FACTS

The case arose from the fatal shooting of Esmeraldo Fernando on election day, November 9, 1965, in Barrio Sta. Brigida, Mansalay, Oriental Mindoro. The prosecution’s version alleged that accused Jesus Villeza, a policeman in uniform, approached the deceased near a schoolhouse used as a polling place and, after saying “requiza,” immediately shot Fernando despite the latter raising his hands. Co-accused Eulogio Jalos also fired, hitting Fernando, while Mayor Sergio Maliwanag fired but missed. The defense, however, presented a starkly different account. Villeza claimed self-defense, testifying that he was handed an arrest order for a person causing trouble, witnessed Fernando assaulting another individual, and attempted to arrest him. Fernando allegedly then drew a balisong knife, slashed at Villeza (hitting only his uniform), and Villeza shot him in response. When Fernando attempted to stab again, Villeza fired a second, fatal shot. Jalos claimed he fired his gun in the air to disperse a crowd, and Maliwanag denied presence. The trial court acquitted Maliwanag and Jalos but convicted Villeza of murder, sentencing him to life imprisonment.

ISSUE

Whether the trial court erred in rejecting appellant Jesus Villeza’s claim of self-defense and in convicting him of murder.

RULING

The Supreme Court reversed the conviction and acquitted Jesus Villeza. The Court found the trial court’s conclusion that the balisong knife was a “planted or fabricated” piece of evidence to be without basis, as it was contradicted by testimony, including from a prosecution witness, that the knife was surrendered to authorities after the incident. The failure to produce the knife in court did not discredit the defense, as there was no evidence Villeza suppressed it; he had relinquished it. On the central claim of self-defense, the Court held that Villeza’s version was clear and convincing. The evidence established that Fernando was creating a disturbance, an arrest order was issued, and when Villeza, a peace officer, attempted to effect the arrest, Fernando unlawfully attacked him with a lethal weapon. This constituted actual aggression, creating a real danger to Villeza’s life, justifying his responsive use of force. The prosecution’s evidence failed to overcome the constitutional presumption of innocence and prove guilt beyond a reasonable doubt. Consequently, the Court ruled that Villeza acted in complete self-defense.