People v. Hisugan
REITERATIONFacts
The Antecedents: On May 13, 1971, Ricardo Jayme, the barrio captain, was at the wharf in Pagadian City. While conversing with Restituto Teledorio, Filomeno Hisugan appeared from behind, grabbed Ricardo by the shoulders, locked his right hand around Ricardo's neck in a stranglehold, and stabbed him twice with a hunting knife. The first stab was to the stomach, and the second, which lodged the knife in the victim's back, was to the left side. Ricardo fell to the ground. Hisugan then attempted to escape by jumping into the sea and swimming towards a boat, but later swam to another boat. Patrolman Monterola arrived, saw the victim, and was informed by Teledorio that Hisugan was the assailant. Monterola apprehended Hisugan, who was in the water holding onto a pumpboat. The victim was brought to a hospital and later declared dead. The post-mortem revealed two stab wounds, with the cause of death being internal hemorrhage. It was also established that sons of the victim, Ric and Boy Jayme, had previously inflicted bodily injuries on Hisugan on March 19, 1970, and Hisugan had filed a frustrated homicide case against them. Procedural History: The Court of First Instance of Zamboanga del Sur found Filomeno Hisugan guilty beyond reasonable doubt of murder and sentenced him to life imprisonment, to indemnify the heirs of the victim, and to pay moral damages. The court found no mitigating or aggravating circumstances. The Petition: The accused appealed the decision, claiming self-defense and alleging that the trial court erred in giving credit to prosecution witnesses, in finding treachery and evident premeditation, and in discrediting defense witnesses.
Issue(s)
Whether the accused is guilty of murder, considering self-defense. Whether the accused is guilty of murder, considering the element of unlawful aggression, reasonable necessity of the means employed, and provocation. Whether the killing was attended by treachery.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance, finding the accused guilty of murder. The plea of self-defense was rejected.
Ratio Decidendi
On the issue of self-defense: The Court reiterated the well-settled rule that he who admits inflicting the injuries causing death bears the burden of proving self-defense with sufficient and convincing evidence. The Court found the appellant's version of self-defense incredible. The trial court's reasons for discrediting the defense included the unlikelihood of a barrio captain taking the law into his own hands in a public place, the possibility of the accused having more reason for revenge, and the fact that the deceased was allegedly unarmed when he threatened the accused. Furthermore, the accused's initial statement to Patrolman Monterola did not mention being collared by the deceased, but rather a previous incident. On the issue of unlawful aggression, reasonable necessity of the means employed, and provocation: The Court found the unlawful aggression imputed upon the deceased to be belied by the testimonies of the state witnesses. The prosecution witnesses testified that the appellant came from behind and stabbed the victim suddenly, contradicting the defense's claim that the deceased collared the appellant and threatened him. Without established unlawful aggression, the plea of self-defense, even incomplete self-defense, must fail. The Court found the element of reasonable necessity of the means employed wanting as well. There was no evidence that the deceased was armed, and other than the appellant's allegation of being collared, there was no necessity to use a knife. The appellant's claim that he could not have used his right arm due to previous injuries further supported the prosecution's version that the stabbing was done with the left hand, consistent with the wounds sustained by the victim. The Court also found that the third requisite of self-defense, the absence of provocation, was not met. The circumstances surrounding the incident did not indicate that the appellant acted without provocation. On the issue of treachery: The Court found that treachery was present. The prosecution witnesses testified that the appellant appeared from behind and stabbed the victim suddenly. The medical examiner testified that the stab wounds could have been inflicted by a left-handed assailant if the victim was at the assailant's left side or at the back. Considering the appellant's admission that his right arm was previously injured and the prosecution's account of the attack from behind, the Court concluded that the appellant insured the killing of the victim without risk to himself, thus establishing treachery.
Main Doctrine
The plea of self-defense must be proven with sufficient and convincing evidence. If such evidence is of doubtful veracity, and not clear and convincing, the defense must fall. The accused, having admitted the infliction of injuries causing death, bears the burden of proving the justifying circumstance claimed.