G.R. No. L-4059 October 23, 1951
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TEOFILO OGBAC, defendant-appellant.

FACTS

Teofilo Ogbac was charged with murder for the killing of Angel Jamilla. The incident occurred on the night of August 12, 1949, during a political meeting in Pinamalayan, Mindoro. While a speaker, Alfredo Mendoza, was addressing the crowd, he was interrupted by Nicolas Jamilla. Irked by this, Ogbac struck Nicolas Jamilla. After order was restored and Mendoza agreed to an amicable settlement proposed by the victim, Angel Jamilla (uncle of Nicolas), Ogbac, who was standing behind Angel, suddenly hooked Angel’s neck with his left arm and stabbed him in the back with a balisong knife, causing instant death. The autopsy revealed a deep penetrating wound at the back. The defense claimed self-defense, alleging that Angel Jamilla, who was drunk, first thrust a knife at Ogbac, and during a grapple, the fatal wound was accidentally inflicted by the deceased’s own knife. The trial court found Ogbac guilty of murder and sentenced him to life imprisonment.

ISSUE

Whether the trial court correctly convicted Teofilo Ogbac of murder, rejecting his claim of self-defense.

RULING

The Supreme Court affirmed the conviction. The Court found the defense’s version of events, particularly the demonstrations of how the wound was inflicted during a grapple, to be inconsistent with the nature, location, and depth of the wound described in the autopsy report. The wound’s characteristics tallied with the prosecution’s account of a sudden stabbing from behind. The Court deferred to the trial court’s assessment of witness credibility and its finding that the prosecution’s version was more credible and harmonious with the circumstances. The offense was murder qualified by treachery, with no mitigating or aggravating circumstances present, warranting the penalty of reclusion perpetua.