People v. Saure
REITERATIONFacts
The Antecedents: On July 28, 1996, at around 1:30 a.m., in Barangay Basak, Maasin, Southern Leyte, Renato Lepasanda was fatally stabbed during a benefit dance. An Information for murder was filed against Ramonito Saure a.k.a. "Dodong". The prosecution alleged that Saure, armed with a "Batangas" knife, attacked Lepasanda from behind after a verbal altercation regarding Lepasanda reprimanding Saure for forcing Arlene Lacbayo to dance. Saure allegedly stabbed Lepasanda multiple times, causing his instantaneous death. Procedural History: The accused pleaded not guilty. The prosecution presented witnesses Eleno Alinsub and Ernesto Lacbayo, the knife, and the victim's Certificate of Death. The defense presented the accused and three corroborating witnesses. The trial court found the accused guilty of murder, appreciating the mitigating circumstance of voluntary surrender, and sentenced him to reclusion perpetua. The court found the prosecution witnesses more credible than the defense witnesses and disregarded the claim of self-defense. The Petition: The accused appealed, contending that the trial court erred in not appreciating his claim of self-defense and in holding that the killing was attended by treachery and evident premeditation.
Issue(s)
Whether the accused-appellant successfully proved the justifying circumstance of self-defense. Whether the killing was attended by treachery. Whether evident premeditation was present.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused-appellant Ramonito "Dodong" Saure guilty beyond reasonable doubt of the crime of murder. He was sentenced to suffer the indivisible penalty of reclusion perpetua and to pay P50,000.00 as civil indemnity to the heirs of the victim.
Ratio Decidendi
On the issue of self-defense: The Court held that the accused-appellant failed to discharge the burden of proving self-defense by clear and convincing evidence. Unlawful aggression, a prerequisite for self-defense, was not established. The accused's claim that the victim struck him first with a stool was found to be self-serving and inconsistent with his initial statement to the police that he did not know who attacked him. Furthermore, his failure to inform the police about acting in self-defense upon his surrender was deemed fatal to his claim. The presence of multiple stab wounds (five in this case) also negated self-defense, indicating a determined effort to kill the victim, not merely to repel an aggression. The testimonies of the defense witnesses, Remigio Lacerna and Matias Sumampong, were found incredible by the trial court and the Supreme Court saw no reason to disturb this finding, as they failed to overcome the positive and straightforward declarations of the prosecution witnesses. The Court reiterated that appellate courts generally do not disturb the findings of the trial court on credibility unless certain facts of substance and value were plainly overlooked. On the issue of treachery: The Court found treachery to be present. The accused-appellant stealthily and without warning attacked the victim from behind while the victim was seated and unaware of the impending danger. Even after a verbal altercation, the victim had reason to believe the matter was settled. The accused-appellant pursued the victim even as he tried to run away and repeatedly stabbed him, demonstrating a conscious effort to ensure the execution of the crime without risk to himself. This mode of attack tended directly and specially to insure the execution of the crime without risk to the offender arising from any defense the offended party might make. On the issue of evident premeditation: The information alleged evident premeditation, but the lower court did not rely on this circumstance to sustain the conviction for murder, nor was it appreciated as a general aggravating circumstance. The Supreme Court's affirmation of murder was based on treachery, not evident premeditation. Therefore, this issue was not extensively discussed as a basis for the conviction in the appellate court's decision.
Main Doctrine
The claim of self-defense requires proof that the accused was not the unlawful aggressor, that there was lack of sufficient provocation, and that reasonable means were employed to repel aggression. Failure to inform the police of the self-defense claim upon surrender is fatal to the defense. The presence of multiple stab wounds negates self-defense.