PEOPLE v. MANZANO and MANZANO, G.R. No. 217974 | 2018 - Synopsis Only

-
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee,
-versus-
RESURRECION JUANILLO MANZANO, JR. AND REZOR JUANILLO MANZANO, ACCUSED, 
REZOR JUANILLO MANZANO, Accused-Appellant.
G.R. No. 217974, THIRD DIVISION, March 05, 2018,

Full text: 

Ponente: MARTIRES, J.

Doctrine:

It is vigorously underscored that the pith and soul of the justifying circumstance of self-defense is the presence of unlawful aggression; thus, the absence of this requisite readily converts the claim of self-defense into nothingness even with the existence of the other elements because the two other essential elements of self-defense would have no factual and legal bases without any unlawful aggression to prevent or repel.55 As case law puts it, there can be no self-defense unless the victim committed unlawful aggression against the person who resorted to self-defense.

Synopsis:

In the case, the accused-appellant was charged with murder before the Regional Trial Court of San Jose, Antique, for the death of Lucio Silava. The accused-appellant pleaded not guilty during the arraignment and raised the justifying circumstance of self-defense.

There were two versions of the story presented. The version of the defense provided that the accused-appellant saw Lucio throwing stones at his house, and when he confronted him, Lucio attempted to stab him with a knife. The accused-appellant claimed that he was able to take hold of the knife and stabbed Lucio in self-defense.

However, the prosecution presented a different version of events. According to their version, the accused-appellant and his brother called out to Lucio and his wife, who were inside their store, and asked to buy cigarettes. Lucio let them in, and the accused-appellant proceeded to where Lucio was having dinner. The accused-appellant's brother changed his mind about buying cigarettes and went towards the kitchen. Lucio was heard asking, "What wrong have I committed?" before Victoria, his wife, saw him bloodied and leaning on the door. She then saw the accused-appellant and his brother stabbing Lucio. The accused-appellant and his brother ran towards the farm after the incident.

The court ruled that the justifying circumstance of self-defense could not be appreciated in this case because there was no unlawful aggression on the part of the victim. The accused-appellant failed to establish the concurrence of the three elements of unlawful aggression:
(a) there must be a physical or material attack or assault; 
(b) the attack or assault must be actual, or, at least, imminent; and 
(c) the attack or assault must be unlawful. The evidence provided by the prosecution, which is a picture of the victim’s blood splattered in their kitchen, belies the contention of self-defense.

The court also ruled that the accused-appellant was guilty of murder, with the qualifying circumstance of treachery and abuse of superior strength. The court found that the accused-appellant and his brother were the aggressors, and their actions were indicative of a determined effort to kill and not just to defend.

Lastly, the court did not appreciate the mitigating circumstance of voluntary surrender because the accused-appellant did not surrender immediately after the commission of the crime. The accused-appellant only surrendered to the police authorities the following day after the incident.

Dispositive portion:

WHEREFORE, the appeal is DISMISSED. The assailed Decision of the Court of Appeals in CA-G.R. CR-HC No. 01473 finding the accused­ appellant Rezor Juanillo Manzano guilty beyond reasonable doubt of Murder and sentencing him to suffer the penalty of reclusion perpetua is AFFIRMED but with MODIFICATION as to the award of damages to the heirs of Lucio Silava, as follows: civil indemnity of P75,000.00; moral damages of P75,000.00; exemplary damages of P75,000.00; and temperate damages of P50,000.00. In addition, interest at the rate of six percent (6%) per annum shall be imposed on all monetary awards from the date of finality of this decision until fully paid.

 

CASE LISTS HERE