PEOPLE v. SIEGA, G.R. No. 213273 | 2018
834 Phil. 500
G.R. No. 213273. June 27, 2018
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE,
V.
LEONARDO B. SIEGA, ACCUSED-APPELLANT.
Ponente: CAGUIOA, J:
Nature of petition:
On appeal is the Amended Decision[1] dated November 20, 2013 of the Court of Appeals (CA), Special Former Nineteenth Division, Cebu City, in CA-G.R. CR HC No. 01003, modifying the Decision[2] dated July 27, 2012 of the CA Nineteenth Division in the same case. The July 27, 2012 Decision of the CA affirmed with modification the Decision[3] of the Regional Trial Court (RTC), Branch 39, Sogod, Southern Leyte, in Criminal Case No. R-478; finding accused-appellant Leonardo B. Siega (Siega) guilty beyond reasonable doubt of the crime of Murder.
Dispositive Portion:
WHEREFORE, the appeal is DISMISSED. The Amended Decision dated November 20, 2013 of the Court of Appeals in CA-G.R. CR-HC No. 01003 finding accused-appellant Leonardo B. Siega GUILTY beyond reasonable doubt of the crime of Murder, defined and penalized under Article 248 of the Revised Penal Code, as amended, is hereby AFFIRMED with MODIFICATION. Accused-appellant is sentenced to suffer the penalty of reclusion perpetua, without eligibility for parole, and ordered to pay the heirs of Pacenciano Bitoy the following amounts: (a) P75,000.00 as civil indemnity; (b) P75,000.00 as moral damages; (c) P75,000.00 as exemplary damages; and (d) P50,000.00 as temperate damages. All monetary awards shall earn interest at the legal rate of six percent (6%) per annum from the date of finality of this Resolution until fully paid.
SO ORDERED.
Carpio (Chairperson),[*] Peralta, Perlas-Bernabe, and A. Reyes, Jr., JJ., concur.
Doctrines:
An accused, who pleads self-defense, has the burden of proving, with clear and convincing evidence, that the killing was attended by the following circumstances: (1) unlawful aggression on the part of the victim; (2) reasonable necessity of the means employed to prevent or repel such aggression; and (3) lack of sufficient provocation on the part of the person resorting to self-defense. Of these three, unlawful aggression is most important and indispensable. Unlawful aggression refers to "an actual physical assault, or at least a threat to inflict real imminent injury, upon a person." Without unlawful aggression, the justifying circumstance of self-defense has no leg to stand on and cannot be appreciated.
Synopsis:
In the case of People of the Philippines vs. Leonardo B. Siega, the defendant appealed his conviction for murder after he stabbed Pacenciano Bitoy to death. Siega claimed self-defense, but the court found that he failed to prove that Bitoy posed an actual, sudden, or imminent threat to his life. Siega's version of events was contradicted by Alingasa's credible testimony that Bitoy did not have a weapon at the time of the incident, which was corroborated by the fact that no weapon was found on the victim. Even if Siega's account were true, the court found that there was no imminent danger to Siega's life that would have justified his use of deadly force.
The court also ruled that treachery attended the killing of Bitoy, which is a qualifying circumstance of murder. Treachery is defined as a sudden and unexpected attack against an unarmed and unsuspecting victim who has no chance to defend himself. In this case, a credible eyewitness testified that Siega, armed with a bolo, stabbed Bitoy on the chest several times while the latter was conversing with Alingasa. The attack was so sudden and unexpected that Bitoy had no chance to defend himself and was felled by Siega's repeated hacking blows.
In conclusion, the Court upheld Siega's conviction for murder, as he failed to prove self-defense and his attack on Bitoy was treacherous. This case serves as a reminder that the burden of proof lies with the accused in a claim of self-defense, and that the presence of treachery can elevate a charge of homicide to murder.