G.R. No. L-6972; April 29, 1955
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MAXIMO SATURNINO, defendant-appellant.

FACTS

On May 28, 1952, between 9:00 and 10:00 a.m., defendant Maximo Saturnino struck Marcelino Valdez on the left side of the head with a wooden club wrapped in a newspaper. The blow caused a lacerated wound and a depressed fracture, leading to intracranial hemorrhage, shock, paralysis, and cerebral concussion, which resulted in Valdez’s death minutes later. Saturnino pleaded self-defense, claiming that as he walked past an autobus, Valdez accosted him with a bolo, asked why Saturnino was trying to waylay him, and advanced towards him. Saturnino alleged he retreated, picked up a piece of wood, and struck Valdez when Valdez gave a bolo thrust. The prosecution witnesses (Procesa Morales, Alipio Miguel, and Gregorio Mateo) testified that Valdez was conversing and joking with them while standing at the entrance of a parked autobus when Saturnino approached from behind and struck him without warning. The Court of First Instance of Ilocos Norte rejected the plea of self-defense, found Saturnino guilty of murder, and sentenced him to reclusion perpetua, indemnification of the heirs of the deceased in the sum of P6,000, and payment of costs.

ISSUE

Whether or not the plea of self-defense has been established satisfactorily.

RULING

No. The plea of self-defense was not established satisfactorily. The Supreme Court affirmed the decision of the lower court, finding Saturnino guilty of murder qualified by treachery. The Court found the testimony of the prosecution witnesses credible and consistent with their affidavits made immediately after the occurrence, and noted they had no motive to testify falsely. The defense’s claim was found unworthy of credence. The alleged bolo was not introduced in evidence and was not seen by any peace officer or impartial person at the scene. Valdez had no reason to attack Saturnino. Furthermore, Saturnino had a motive to commit the crime, as Valdez had previously inflicted injuries on him, and Saturnino had remarked he would “get even” with Valdez after their attempted settlement failed. The Court also held that the mitigating circumstances of voluntary surrender and an offer to plead guilty were not applicable. There was no competent evidence of voluntary surrender, as Saturnino was apprehended by officers who had to look for him. His offer to plead guilty was qualified and for a lesser crime (homicide) than the one committed (murder). The decision of the lower court was affirmed.