G.R. No. L-47228 and L-46587, December 15, 1986
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NAPOLEON MARANAN Y ANGCO, defendant-appellant. / NAPOLEON A. MARANAN, petitioner, vs. HONORABLE ONOFRE A. VILLALUZ, respondent.

FACTS

Two sets of informations were filed against Napoleon Maranan concerning the same hacking incident on February 1, 1977, in Amadeo, Cavite. The first set, five cases for Murder, Frustrated Murder, and Attempted Murder, was filed in the Circuit Criminal Court of Pasig. The second set, for Murder, Double Murder, and Slight Physical Injuries, was filed in the Court of First Instance of Cavite. Maranan moved to dismiss the Pasig cases, arguing the Cavite court had acquired jurisdiction. However, he pleaded not guilty in Pasig, and trial commenced. He then filed a petition for certiorari with the Supreme Court (G.R. No. L-46587) to restrain the Pasig court. Pending this petition, the Pasig court rendered a decision convicting him and imposing the death penalty, leading to automatic review (G.R. No. L-47228).
The prosecution evidence established that Maranan, armed with a bolo, suddenly and successively hacked five victims who were conversing on a street corner, killing Isaias Bayani and seriously injuring the others. The attack was allegedly motivated by a long-standing grudge stemming from a prior crime against Maranan’s sister. The defense version claimed self-defense, alleging the victims initiated an armed assault, and he hacked them to save his life. He admitted hacking all victims but claimed he was unarmed at the start and escaped after the incident.

ISSUE

The primary issue is whether the trial court correctly rejected Maranan’s claim of self-defense and found him guilty of the crimes charged. A subsidiary procedural issue is whether the Circuit Criminal Court of Pasig validly exercised jurisdiction over the cases.

RULING

The Supreme Court affirmed the conviction. On the substantive issue, the Court upheld the trial court’s finding that the prosecution’s version was more credible. Self-defense requires clear and convincing proof, which the appellant failed to provide. His testimony was inherently improbable, as he claimed to have single-handedly overpowered and hacked five armed assailants without sustaining a single injury. His immediate flight after the incident and failure to report to authorities are conduct inconsistent with self-defense but indicative of guilt. The sudden, unexpected nature of the attack established treachery, qualifying the killing to murder. The intent to kill was evident from the lethal wounds inflicted.
On the procedural issue, the Court ruled the Circuit Criminal Court of Pasig validly exercised jurisdiction. Under Republic Act No. 5179 , as amended, it had jurisdiction over offenses committed within the judicial district, which included Cavite. Its jurisdiction was concurrent with the Court of First Instance of Cavite. Since the informations were filed in the Pasig court on June 21, 1977, and in the Cavite court only on June 23, 1977, the Pasig court acquired exclusive jurisdiction by priority in filing. Thus, the certiorari petition was dismissed. The death penalty was reduced to reclusion perpetua due to lack of necessary votes, and civil indemnity was increased to P30,000.00.