G.R. No. L-39942. April 26, 1982.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARTURO MANZURES, defendant-appellant.

FACTS

The case originated from the fatal stabbing of Cesar Valenzuela on November 15, 1969, in Surallah, South Cotabato. According to the prosecution, while Valenzuela was with his sweetheart, Milagros Eliseo, at a dance hall, Gerardo Malfarta suddenly stabbed him in the right arm. Immediately thereafter, Arturo Manzures, Malfarta’s cousin, grappled with Valenzuela and stabbed him in the abdomen. Valenzuela fell, managed to kick Manzures, and was later brought to the hospital where he died. The autopsy revealed the abdominal wound affected vital organs, and the physician testified the wounds were inflicted by two different bladed weapons.
Both accused were convicted of murder by the trial court and sentenced to reclusion perpetua. Malfarta withdrew his appeal, leaving Manzures as the sole appellant. At trial, Manzures claimed self-defense, alleging Valenzuela attacked him first, and that he used Valenzuela’s own knife to wound him. He also challenged the credibility of eyewitness Milagros Eliseo.

ISSUE

The core issue is whether the trial court erred in convicting Arturo Manzures of murder, rejecting his claim of self-defense and upholding the credibility of the prosecution’s evidence.

RULING

The Supreme Court affirmed the conviction. The Court meticulously examined the records and found the testimony of eyewitness Milagros Eliseo to be credible and consistent with her prior statement, directly contradicting the claim of self-defense. The Court emphasized that for self-defense to be valid, unlawful aggression by the victim must be proven. Here, the physical evidence contradicted Manzures’ narrative; the only injury he sustained was a contusion on the thigh, which was grossly disproportionate to his description of a severe life-threatening attack by Valenzuela that allegedly rendered him unconscious. This discrepancy exposed the fabricated nature of his plea.
The Court also dismissed Manzures’ ancillary arguments, including the doctor’s opinion on the weapons, the lack of proven motive, the non-production of the weapon, and the failure to present the barrio captain. These were deemed insufficient to cast reasonable doubt on his guilt, as his identity as the one who inflicted the fatal abdominal wound was established beyond reasonable doubt. The killing was correctly classified as murder qualified by treachery, as the attack was sudden and rendered the victim defenseless. No aggravating or mitigating circumstances attended the crime, making reclusion perpetua the appropriate penalty. The Court modified the indemnity to reflect solidary liability with his co-accused.