PEOPLE OF THE PHILIPPINES VS. ROMEO SATONERO RUBEN G.R. No. 186233, October 2, 2009
Criminal Case Digest / Digested Case
Murder; Self-Defense
FACTS:
At around five o’clock in the afternoon of December 25, 1997, Leticia and her nephew, Ramon Amigable were in Brgy. La Esperanza, Tulunan waiting for a tricycle ride to a place called M’lang. Leticia had just received a gift from her sister. Accused-appellant Romeo SATONERO, Leticia’s nephew too, happened to be nearby. Accused-appellant, upon seeing the gift Leticia was holding, inquired where it came from. When told of the source, accused-appellant mocked the gift-giver for giving more to those who have more in life. Accused-appellant then asked Leticia if she knew who he was, followed by a remark that he would throw her into the irrigation ditch.
At that moment, Leticia told Ramon not to mind accused-appellant because he was drunk. When Ramon was about to board the tricycle, accused-appellant followed him, shot him three times with a short-barreled gun, then stabbed him several times. All told, Ramon sustained nine stab wounds on different parts of his body. Ramon died as a result.
On May 16, 2003, the RTC rendered judgment convicting accused-appellant of murder, discrediting the SATONERO’s theory of self-defense. This was affirmed by the CA.
ISSUE:
Did the RTC and CA err in not appreciating self-defense?
HELD:
No. The conviction was proper. There was no self-defense.
The Court finds no cogent reason to overturn the finding of the CA, confirmatory of that of the RTC, that there was no self-defense on the part of accused-appellant in the instant case.
One who admits killing another in the name of self-defense bears the onus of proving the justifiability of the killing. The accused, therefore, must convincingly prove the following elements of the justifying circumstance of self-defense: (1) unlawful aggression on the part of the victim; (2) reasonable necessity of the means employed to prevent or repel it; and (3) lack of sufficient provocation on the part of the person claiming self-defense. While all three elements must concur to support a claim of complete self-defenese, self-defense relies first and foremost on a showing of unlawful aggression on the part of the victim. Absent clear proof of unlawful aggression on the part of the victim, self-defense may not be successfully pleaded
In the instant case, accused-appellant failed to discharge his burden of proving unlawful aggression. From a perusal of the trial court’s decision, the prosecution’s testimonial evidence, notably Leticia’s testimony, had been carefully weighed and was found by the trial court to be more credible and convincing than the bare and self-serving testimony of accused-appellant as to who initiated the fight and what transpired after the initial assault ensued. The testimony of a single eyewitness to a killing, if worthy of credence, is sufficient to support a conviction for homicide or murder, as the case may be.
The allegation of accused-appellant which pictured Ramon as purportedly pulling out a knife and attempting to stab the former came uncorroborated, although several onlookers––potential witnesses all––were at the situs of the crime. And while claiming to have grappled for some time with Ramon for the possession of the knife, accused-appellant managed to stay unscathed, which in itself is incredible.