G.R. No. L-38687 August 31, 1982
The People of the Philippines, plaintiff-appellee, vs. Filomeno Hisugan, accused-appellant.

FACTS

On May 13, 1971, at the Pagadian City wharf, Ricardo Jayme, the barrio captain, was with his wife Narcisa and a companion, Restituto Teledorio. The accused-appellant, Filomeno Hisugan, suddenly appeared, grabbed Jayme from behind, locked him in a stranglehold, and stabbed him in the stomach and back with a hunting knife. Jayme fell to the ground with the knife embedded in his back. Hisugan then attempted to escape by jumping into the sea. Patrolman Monterola responded, apprehended Hisugan, and recovered the knife. Jayme was pronounced dead at the hospital from internal hemorrhage due to the stab wounds.
Hisugan admitted the killing but claimed self-defense. He testified that Jayme had accosted him at the wharf, demanding he withdraw a criminal case against Jayme’s sons (who had previously injured Hisugan), and had collared and threatened to kill him. Fearing for his life, Hisugan claimed he grabbed a knife from a nearby pushcart and stabbed Jayme. The prosecution witnesses, however, consistently testified that the attack was sudden and from behind.

ISSUE

Whether the trial court correctly convicted the appellant of murder, qualified by treachery, and properly rejected his plea of self-defense.

RULING

The Supreme Court affirmed the conviction for murder. The plea of self-defense was untenable as the appellant failed to prove the essential element of unlawful aggression on the part of the victim. The prosecution evidence established that the assault was sudden and from behind, while the appellant’s own admission about the uselessness of his right arm (due to a prior injury) contradicted his claim of being collared and threatened face-to-face. Without unlawful aggression, the justifying circumstance of self-defense cannot stand.
The killing was qualified by treachery (alevosia). The manner of attack—coming from behind the unsuspecting victim who was conversing with a companion—ensured the execution of the crime without risk to the appellant arising from any defense the victim might make. The location of the wounds, as explained by the medico-legal testimony, corroborated the prosecution’s version that the appellant used his left hand to stab the victim from behind or the side, consistent with a treacherous attack. Therefore, the crime committed was murder, not homicide. The Court found no reason to disturb the factual findings and legal conclusions of the trial court.