People v. Nadyahan
REITERATIONFacts
The Antecedents: Petitioner Rafael Nadyahan was charged with homicide for allegedly stabbing Mark Anthony D. Pagaddut on May 26, 2004. The Information alleged that petitioner, armed with a knife and with intent to kill, willfully, unlawfully, and feloniously attacked and stabbed the victim, causing his death. Procedural History: Petitioner pleaded not guilty and claimed self-defense. A reverse trial was conducted. The defense presented petitioner and Pedro Binwag, who testified that petitioner was flagged down by the victim and his companions, that petitioner refused to buy them drinks, which angered one of the companions who slapped petitioner. Petitioner was then hit with a piece of wood. Petitioner claimed he impulsively took his knife and stabbed the victim while losing consciousness. Pedro Binwag testified seeing a person with a knife being chased and struck with a club, then bumped by another man. The prosecution presented Marcial Acangan and Elias Nabejet, who claimed petitioner was the aggressor, suddenly wielding a knife and chasing them, kicking and stabbing the victim. The victim sustained multiple stab wounds. The RTC found incomplete self-defense and convicted petitioner of homicide. The Court of Appeals affirmed the conviction. The Petition: Petitioner argues that the courts below erred in ruling that there was incomplete self-defense and in sustaining the penalty imposed without considering favorable circumstances.
Issue(s)
Whether the courts erred in ruling that there was incomplete self-defense. Whether the penalty imposed was proper considering the circumstances.
Ruling
The Supreme Court denied the petition, affirming the decision of the Court of Appeals which upheld the conviction of petitioner for homicide. The Court found that while there was unlawful aggression and lack of sufficient provocation, the means employed by the petitioner were not reasonably necessary to repel the attack, thus constituting incomplete self-defense. The penalty imposed by the trial court, as affirmed by the appellate court, was sustained.
Ratio Decidendi
On the issue of incomplete self-defense: The Court affirmed the findings of the lower courts that there was unlawful aggression on the part of the victim and his companions, and a lack of sufficient provocation on the part of the petitioner. The petitioner acceded to a request for a ride and his refusal to buy drinks was not sufficient provocation for the attack. However, the Court found that the element of reasonable necessity of the means employed to prevent or repel the attack was wanting. The disproportion between a knife and a belt buckle, the nature and location of the stab wounds inflicted on the victim (vital parts, deep thrusts), and the fact that petitioner only sustained a lacerated wound on the forehead, all indicated that the use of the knife was not reasonably necessary to repel the aggression. The Court noted that the depth and location of the wounds suggested an intent to kill rather than merely disable the victim. Therefore, while the elements of unlawful aggression and lack of sufficient provocation were present, the absence of reasonable necessity of the means employed meant that self-defense was incomplete. On the issue of penalty: The Court reiterated that for homicide, the prescribed penalty is reclusion temporal. Article 69 of the Revised Penal Code provides for a reduction of the penalty by one or two degrees when the justifying circumstance of self-defense is incomplete. Applying this, the penalty was reduced by one degree from reclusion temporal to prision mayor. Considering the presence of voluntary surrender as an ordinary mitigating circumstance, the penalty was imposed in its minimum period. Thus, the trial court correctly imposed the penalty of four (4) years and two (2) months of prision correccional medium, as minimum, to eight (8) years of prision mayor minimum, as maximum, in accordance with the Indeterminate Sentence Law.
Main Doctrine
In invoking self-defense, the onus probandi is on the accused to prove by clear and convincing evidence all the elements of the justifying circumstance: (a) unlawful aggression on the part of the victim; (b) the 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. Incomplete self-defense, while a privileged mitigating circumstance, requires that at least one of these elements be present, but not all.