G.R. No. L-38175 September 28, 1984
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMEO LACHICA and JILLY SIGADOR, accused-appellants.

FACTS

Accused-appellants Romeo Lachica and Jilly Sigador, both prisoners at the New Bilibid Prison, were charged with the murder of fellow inmate Dominador Aguilar inside his cell on March 28, 1971. The prosecution evidence established that Lachica and Sigador, along with another prisoner, planned the killing as revenge for Aguilar’s alleged role as the mastermind in a previous stabbing incident. They entered Aguilar’s dormitory, and Lachica initially stabbed the seated victim. When Aguilar attempted to flee, Sigador pursued and stabbed him repeatedly, resulting in Aguilar’s death from multiple wounds. The assailants subsequently surrendered to a prison guard and voluntarily surrendered the knives used. Both accused initially pleaded guilty to the charge.
At trial, Lachica changed his narrative, claiming he acted in self-defense. He testified that he went to Aguilar’s dormitory to watch television and bet on horse races, an altercation ensued, and Aguilar threatened him by saying, “Baka hindi ka na makalabas nang buhay dito.” Fearing for his life, Lachica claimed he preemptively stabbed Aguilar. The trial court found both accused guilty of murder and imposed the death penalty. As Sigador had already been executed for a previous crime, the review proceeded only for Lachica.

ISSUE

Whether the trial court correctly convicted Romeo Lachica of murder, and whether the mitigating circumstance of self-defense or any error in the proceedings warrants a reversal of the judgment.

RULING

The Supreme Court affirmed Lachica’s conviction for murder but commuted the penalty to reclusion perpetua. The Court rejected the claim of self-defense. For self-defense to be valid, unlawful aggression by the victim must be proven as a primordial element. The Court found that Aguilar’s mere verbal threat, without any showing that he was armed or made an actual imminent attack, does not constitute unlawful aggression. Lachica’s preemptive stabbing of an unarmed and seated victim cannot be justified.
The Court upheld the finding of treachery and evident premeditation, as the attack was deliberate, sudden, and rendered the victim defenseless. The Court also noted Lachica’s judicial confession, given during the investigation, which strongly evidenced his guilt. While his counsel argued this confession was obtained without being informed of his rights, the Court ruled it was admissible as it was taken before the effectivity of the 1973 Constitution. Furthermore, Lachica was correctly considered a quasi-recidivist under Article 160 of the Revised Penal Code, as he committed this murder while serving sentence for previous crimes, which justifies the imposition of the maximum penalty. However, due to the lack of necessary votes for the death penalty, it was commuted to reclusion perpetua. He was also ordered to pay indemnity to the victim’s heirs.