G.R. No. L-41061 July 16, 1990
WILLIAM GUEVARRA, petitioner, vs. COURT OF APPEALS and PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner William Guevarra was charged with homicide for stabbing Jaime Alvarez, who died two days after the incident. The prosecution’s evidence established that on January 1, 1965, Guevarra went to the victim’s house looking for him. Later that afternoon, the victim was seen being chased by Guevarra and two other men. The victim fell, and while lying down, was hacked and stabbed by the group. The defense, however, interposed self-defense. Guevarra testified that he went to the victim’s house to report an incident involving his niece. Later, while at a store, the victim allegedly approached him from behind, uttered invectives, and attempted to hack him with a jungle bolo. Guevarra claimed he was wounded in the hand and, in the ensuing struggle, managed to grab a bladed instrument from a vendor’s stall and stab the victim in defense.
The trial court convicted Guevarra of homicide, sentencing him to an indeterminate penalty and ordering indemnity. The Court of Appeals affirmed the decision. Guevarra elevated the case to the Supreme Court, arguing that the lower courts erred in not appreciating self-defense.

ISSUE

Whether the petitioner acted in lawful self-defense when he stabbed the victim.

RULING

The Supreme Court denied the petition and affirmed the conviction, with modifications to the penalty and indemnity. The Court held that self-defense was not sufficiently proven. For self-defense to be valid, the accused must prove three elements: (1) unlawful aggression by the victim; (2) reasonable necessity of the means employed to repel it; and (3) lack of sufficient provocation from the defender. Unlawful aggression is the indispensable foundation. The petitioner’s claim that the victim was the unlawful aggressor hinges on a factual question. The trial court, which is in the best position to assess witness credibility, found the prosecution’s version more credible. The Court noted the defense presented no corroborating witnesses to substantiate the claim of unlawful aggression. The petitioner’s lone testimony, deemed insufficient to clearly and convincingly establish that the victim initiated a sudden and unprovoked attack, failed to overturn the presumption that the killing was unlawful.
However, the Court recognized two mitigating circumstances: sufficient provocation on the part of the victim (for uttering invectives) and voluntary surrender by the petitioner. With two mitigating and no aggravating circumstances, the penalty for homicide (reclusion temporal) was reduced by one degree to prision mayor, imposed in its medium period. Applying the Indeterminate Sentence Law, the minimum was set within prision correccional and the maximum within the medium period of prision mayor. The indemnity to the victim’s heirs was increased from P6,000.00 to P30,000.00. The judgment of conviction was thus AFFIRMED with these modifications.