People v. Maruhom
REITERATIONFacts
The Antecedents: On January 6, 1966, at Gapao Balindong, Taraka, Lanao del Sur, the victim, Mansongayan Osmena, boarded a launch. While entering the passenger compartment, the accused, Bala Maruhom, called him from the rooftop of the launch, asking to talk. As the victim looked up, the accused fired his Caliber 38 Revolver, hitting the victim on the left temporal aspect of his head. The victim fell, and the accused jumped to the river bank and fled. The victim's wife reported the incident to the PC. A Medico-Legal Necropsy Report noted a gunshot wound of entrance at the left temporal aspect of the head, with no exit wound, as opening the skull was refused by the victim's relatives. Procedural History: The accused was apprehended after a three-day siege of his hideout. He claimed self-defense, stating the victim drew a gun and attempted to fire at him twice, but the gun failed to explode. The accused then fired at the victim. He claimed he fled due to fear of reprisal and intended to surrender but could not find a motorboat. He was eventually apprehended and detained. The trial court convicted the accused of murder, sentencing him to reclusion perpetua and ordering him to indemnify the heirs. The Petition: The accused appealed, arguing the trial court erred in giving weight to the testimonies of the victim's wife and daughter, disregarding defense witnesses, and failing to acquit him despite self-defense. He also contended that treachery was not present and that voluntary surrender should have been credited.
Issue(s)
Whether the appellant acted in self-defense. Whether treachery attended the commission of the offense. Whether the appellant is entitled to the mitigating circumstance of voluntary surrender.
Ruling
The Supreme Court affirmed the conviction of the accused-appellant for murder, with modification to the indemnity awarded to the heirs. The Court ruled that self-defense was not sufficiently proven, treachery was present, and the surrender was not voluntary.
Ratio Decidendi
On the issue of self-defense: The Court held that the appellant failed to prove self-defense by clear and convincing evidence. The existence of the gun allegedly used by the victim was not substantiated, and the testimonies of the defense witnesses regarding the gun were contradictory. Furthermore, the location of the gunshot wound on the victim's left temporal aspect of the head was inconsistent with the appellant's claim of facing the victim. The appellant's act of going into hiding immediately after the incident, instead of reporting to the authorities and invoking self-defense, also cast serious doubt on his claim. The Court reiterated that flight is an indication of guilt. On the issue of treachery: The Court found that treachery attended the commission of the offense. The attack was sudden and unexpected, rendering the victim immune from any retaliatory attack. The circumstances under which the appellant killed the victim, by firing at him while he was looking up after being called, ensured that the victim could not defend himself. The Court clarified that while there was animosity between the parties, there was no evidence of evident premeditation. On the issue of voluntary surrender: The Court ruled that the appellant's surrender was not voluntary but compelled. He surrendered only after his hideout was cordoned, escape routes were blocked, and he was likely suffering from hunger and the elements. This was not the kind of spontaneous surrender that warrants mitigation of criminal liability; it was a surrender born out of necessity and the inevitability of capture. The Court emphasized that for surrender to be mitigating, it must be spontaneous and indicative of a desire to account for one's actions.
Main Doctrine
Self-defense must be proven by clear and convincing evidence, and the presence of unlawful aggression is a prerequisite. Flight and failure to immediately invoke self-defense cast doubt on the claim. Voluntary surrender requires spontaneity, not mere compulsion due to imminent capture.