G.R. No. L-66551 April 25, 1985
PEOPLE OF THE PHILIPPINES, plaintiff-appellee vs. ANTONIO DANIEL Y VERONA, defendant-appellant.

FACTS

The prosecution’s evidence established that on the evening of January 21, 1982, in Quezon City, appellant Antonio Daniel chased the victim, George Angcahas, along Mariveles Street. Eyewitness William Osorio testified that he saw appellant overtake the victim, place a hand on his shoulder, and stab him in the chest. The victim was declared dead on arrival at the hospital. The autopsy confirmed the cause of death as a stab wound to the trunk. Appellant was apprehended three days later and gave a written statement admitting to the stabbing.
The defense, however, presented a different version. Appellant claimed he was selling taho when the victim demanded money from him. He testified that when he refused, the victim drew a knife and attempted to stab him. A struggle ensued, and during the grapple for the knife, it accidentally pierced the victim’s chest. Appellant asserted he acted in self-defense and that his extrajudicial confession was given under duress.

ISSUE

The primary issue is whether the killing was attended by the qualifying circumstance of evident premeditation to constitute Murder, or if the appellant’s claim of self-defense is credible, thereby exculpating him from criminal liability.

RULING

The Supreme Court modified the trial court’s decision, convicting the appellant of Homicide instead of Murder. The Court found the prosecution successfully proved the killing but failed to establish the qualifying circumstance of evident premeditation with the required moral certainty. For evident premeditation to qualify a killing to murder, the prosecution must prove: (1) the time when the offender determined to commit the crime; (2) an act manifestly indicating that the offender clung to his determination; and (3) a sufficient lapse of time between the determination and execution to allow the offender to reflect upon the consequences of his act. The evidence on record did not convincingly show these elements.
Regarding the claim of self-defense, the Court ruled it was unavailing. When an accused invokes self-defense, the burden of proof shifts to him to establish its elements by clear and convincing evidence. Appellant’s testimony was found insufficient and inconsistent with the physical evidence, particularly the nature and location of the single, fatal stab wound. His claim of a sudden, unprovoked attack followed by a struggle was not credible. The extrajudicial confession, given after being apprised of his rights and containing details only the perpetrator would know, was deemed voluntary and admissible. Consequently, appellant is guilty of Homicide, qualified by none of the circumstances in Article 248 of the Revised Penal Code. The penalty was modified accordingly, and civil indemnities were awarded to the victim’s heirs.