People v. Gumayao
REITERATIONFacts
The Antecedents: On December 28, 1996, at around 10:00 to 10:45 p.m., Concordio Sulogan and Diocrly Binayao were sitting by the Syre Highway in Kalasungay, Malaybalay City, watching a disco party. Jerryvie Gumayao approached and joined them, sitting beside Concordio. Edmund Paano briefly greeted Concordio and left. Immediately thereafter, Jerryvie Gumayao allegedly drew a knife and stabbed Concordio twice in the chest and abdomen, causing mortal wounds. Jerryvie fled the scene. Concordio was brought to the hospital but died from his injuries. Procedural History: The Regional Trial Court, Branch 8, Malaybalay City, Bukidnon, convicted Jerryvie Gumayao of murder and sentenced him to reclusion perpetua, ordering him to indemnify the heirs of Concordio Sulogan in the sum of P50,000.00. The Petition: The appellant assailed the RTC decision, arguing that the trial court erred in not appreciating his claim of self-defense, in convicting him despite his evidence, and in convicting him of murder instead of homicide.
Issue(s)
Whether the appellant acted in self-defense when he stabbed the victim. Whether the trial court erred in convicting the appellant of murder instead of homicide, and in its appreciation of the evidence regarding treachery. Whether the trial court erred regarding the penalty and civil liabilities.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court with modification, finding the appellant guilty of murder qualified by treachery and sentencing him to reclusion perpetua. The Court also ordered the appellant to pay the heirs of the victim P50,000.00 as civil indemnity, P50,000.00 as moral damages, and P25,000.00 as temperate damages.
Ratio Decidendi
On the issue of self-defense: The Court held that self-defense is an inherently weak defense that must be proven with clear and convincing evidence. The appellant failed to discharge this burden. Firstly, his flight from the crime scene is a badge of guilt, negating his plea. Secondly, he failed to inform the police of his claim of self-defense immediately after surrendering, only invoking it during trial. Thirdly, the nature and number of wounds (two stab wounds on the chest and abdomen, both fatal) indicated a determination to kill, not merely to repel aggression. Fourthly, the appellant made inconsistent and conflicting statements regarding the events leading to the stabbing, undermining his credibility. The Court reiterated that the accused must rely on the strength of his own evidence, not on the weakness of the prosecution's. On the conviction for murder and appreciation of evidence: The Court found no reason to overturn the trial court's findings of fact, which are accorded great weight. The eyewitness account of Diocrly Binayao, coupled with the victim's death, was sufficient proof beyond reasonable doubt. The prosecution established that the appellant committed murder, qualified by treachery. Treachery exists when the attack is sudden and unexpected, and the victim is not in a position to defend himself. The victim was merely sitting by the road, chatting with a friend, when the appellant, who had joined them, suddenly drew a knife and stabbed him twice in vital parts of the body. This mode of attack ensured the victim's immediate death and was done without any warning or opportunity for the victim to defend himself. The appellant's claim that he was outnumbered and acted in self-defense was not substantiated by credible evidence and was contradicted by his own inconsistent statements and subsequent flight. On the penalty and civil liabilities: The Court affirmed the penalty of reclusion perpetua, noting that voluntary surrender does not affect the penalty for murder, which is an indivisible penalty. The award of P50,000.00 as civil indemnity was affirmed as it needs no other proof than the death of the victim. The Court also awarded P50,000.00 as moral damages and P25,000.00 as temperate damages, noting the lack of receipts for actual damages and the insufficient proof for lost earnings. The victim's widow's testimony regarding his earnings was considered self-serving and lacked unbiased proof of net income.
Main Doctrine
Flight is a veritable badge of guilt and negates the plea of self-defense. The nature and number of wounds inflicted can negate a claim of self-defense and prove intent to kill. Inconsistent statements by the accused weaken the credibility of their defense. The trial court's findings of fact, when supported by evidence, are accorded great weight and even conclusive effect.