People v. Pajabera
REITERATIONFacts
The Antecedents: On May 29, 2003, at around 2:30 PM, in Barangay Pag-asa, Tinambac, Camarines Sur, Majen B. Bolanos was at a cockpit arena. Roberto Pajabera called the victim from behind. When the victim turned, Pajabera placed a hand on his shoulder and stabbed him with a "balisong" from behind, causing him to fall and bleed. The victim sustained a deep penetrating stab wound on his right shoulder, leading to rapid internal and external hemorrhage and his death. Pajabera admitted stabbing the victim but claimed self-defense, alleging the victim refused to pay a wager, pulled out a bladed instrument, and attacked him. Pajabera claimed that during a struggle, he accidentally pushed the bladed instrument towards the victim while lying on his back. A witness, Salvador Habulin, corroborated Pajabera's account. Procedural History: The Regional Trial Court (RTC) of Calabanga, Camarines Sur, Branch 63, found Roberto Pajabera guilty beyond reasonable doubt of Murder, qualified by treachery. The RTC rejected the claim of self-defense, finding it improbable that the victim would be hit on the shoulder given the described positions. The RTC ruled out evident premeditation due to lack of proof of intent. The Court of Appeals (CA) affirmed the RTC decision, holding that Pajabera failed to discharge the burden of proving self-defense by clear and convincing evidence. The Petition: Pajabera appealed to the Supreme Court, essentially asking it to re-weigh the credibility of witnesses and review the factual findings of the lower courts.
Issue(s)
Whether the trial and appellate courts erred in giving full faith and credit to the prosecution witnesses' testimonies over the defense witnesses, and whether appellant's claim of self-defense was sufficiently proven. Whether appellant Roberto Pajabera y Doe is guilty beyond reasonable doubt of Murder, qualified by treachery. What is the proper penalty and what damages are applicable, given the finding of guilt for Murder qualified by treachery.
Ruling
The appeal fails. The Supreme Court affirmed the decision of the Court of Appeals, with modifications on the award of damages. The conviction of Roberto Pajabera for Murder is upheld.
Ratio Decidendi
On the credibility of witnesses and the claim of self-defense: The Supreme Court reiterated the settled rule that the issue of credibility is best addressed to the trial court, and its findings of fact, especially when affirmed by the appellate court, are accorded the greatest respect in the absence of a showing that it ignored, overlooked, or failed to properly appreciate matters of substance. The Court found the testimony of the defense witness, Salvador Habulin, to have lapses on material points, particularly regarding the position of the appellant and the victim during the alleged grappling for the weapon. The Court noted inconsistencies in Habulin's direct and cross-examination testimony concerning whether they were standing or lying down, and how the victim was allegedly hit by his own weapon. Given these lapses, the trial and appellate courts did not err in crediting the version of the prosecution. Furthermore, the Court found Pajabera's claim of self-defense improbable, particularly the assertion that the victim was accidentally stabbed on the shoulder while Pajabera was lying on his back and the victim was kneeling and stooping over him. The Court reasoned that such a position would more likely result in a blow to the chest or stomach, not the shoulder. The burden of proving self-defense by clear and convincing evidence was not discharged by the appellant. On the guilt of appellant for Murder, qualified by treachery: The Supreme Court affirmed the finding that the killing was qualified by treachery. Treachery exists when the attack is deliberate and unexpected, giving the victim no chance to defend himself. The Court noted that the appellant's attack was made in a swift and unexpected manner on the unsuspecting and unarmed victim, who did not give the slightest provocation. This suddenness deprived the victim of any means to defend himself. The Court ruled out evident premeditation due to the absence of proof regarding when the appellant conceived of killing the victim. However, the presence of treachery was sufficient to qualify the killing as Murder. On the penalty and damages: The Court affirmed the penalty of reclusion perpetua, which is proper for Murder when qualified by treachery and absent any aggravating or mitigating circumstances, in accordance with Article 63 of the Revised Penal Code. Reclusion perpetua carries the accessory penalty of perpetual absolute disqualification. Regarding the civil aspect, the Court found the awards of ₱50,000 as civil indemnity and ₱50,000 as moral damages in order, based on prevailing jurisprudence. However, the Court modified the award of actual damages, granting temperate damages of ₱25,000 in lieu of the ₱10,000 actual damages claimed and admitted. Additionally, the Court awarded exemplary damages of ₱25,000, which are in order when an aggravating circumstance, such as treachery, is present in the commission of the crime.
Main Doctrine
The credibility of witnesses is a question best addressed to the trial court, and its findings of fact, especially when affirmed by the appellate court, are accorded the greatest respect. The claim of self-defense must be proven by clear and convincing evidence. Treachery attended the killing when the attack was swift and unexpected, depriving the victim of any means to defend himself.