People v. Supremo
REITERATIONFacts
The Antecedents: On 3 October 1988, at about 4:30 PM, in Sto. Niño, South Cotabato, accused Joseph Supremo allegedly uttered "Bon-on ta karon" (I will kill you) and stabbed Donald "Dodie" Funtecha with a foot-long knife in the abdomen. Prosecution witness Raymundo Billanes, Jr. testified that he was with the victim and intervened when Supremo was about to stab Funtecha again. Accused Supremo, abandoning his alibi, claimed self-defense, stating the victim approached him with marijuana, demanded beer, and later, along with companions, ganged up on him, hitting him and banging his head against a wall, and that he instinctively pulled out his knife and stabbed the victim. Procedural History: The Regional Trial Court of Surallah, South Cotabato, Br. 26, found Joseph Supremo guilty of murder and sentenced him to reclusion perpetua and to indemnify the heirs of the victim. The RTC gave credence to the prosecution witness's testimony over the accused's claim of self-defense, finding the latter's story "quite incredible." The Petition: The accused appealed the RTC decision, clinging to his theory of self-defense and, in the alternative, arguing the absence of treachery. He contended that the trial court erred in disregarding his testimony.
Issue(s)
Whether the accused acted in self-defense. Whether the killing was attended by treachery.
Ruling
The Supreme Court affirmed the conviction but modified the crime from murder to homicide. The accused was sentenced to an indeterminate penalty of six (6) years and one (1) day of prision mayor minimum, as minimum, to fourteen (14) years, eight (8) months and one (1) day of reclusion temporal medium, as maximum. The civil liability was increased to P50,000.00.
Ratio Decidendi
On the issue of self-defense: The Court held that the claim of self-defense could not prosper. For self-defense to be valid, three requisites must be met: (a) unlawful aggression on the part of the victim, (b) reasonable necessity of the means employed to prevent or repel it, and (c) lack of sufficient provocation on the part of the person defending himself. In this case, the established fact, as testified by the prosecution witness and found credible by the trial court, was that the accused stabbed the victim without the victim initiating any unlawful aggression. Therefore, the first requisite for self-defense was absent, leading to the failure of the plea. On the issue of treachery: The Court found the evidence insufficient to hold that treachery accompanied the killing. While the prosecution relied on the suddenness of the attack, the Court reiterated that a sudden and unexpected attack does not automatically equate to treachery. Treachery requires proof that the offender consciously and deliberately adopted a mode of assault that insured the execution of the crime without risk to himself. The prosecution failed to present evidence demonstrating that the accused consciously and deliberately adopted the stabbing as a means to insure the commission of the crime without risk to himself. Therefore, the killing could not be qualified as murder due to the absence of treachery.
Main Doctrine
The Court affirmed the conviction but modified the crime from murder to homicide, finding that while the killing was established, treachery was not sufficiently proven. The claim of self-defense was also rejected due to the absence of unlawful aggression.