In a ruling that clarifies the boundaries of self-defense in homicide cases, the Supreme Court affirmed the conviction of Rezor Juanillo Manzano, Jr. for murder. The Court emphasized that for a claim of self-defense to succeed, the accused must first demonstrate that the victim committed unlawful aggression. This decision underscores the importance of proving imminent danger to one’s life before resorting to lethal force, providing a crucial guide for understanding justifiable self-defense under Philippine law.

Stones, Cigarettes, and Fatal Wounds: Did Self-Defense Justify the Stabbing of Lucio Silava?

The case of People of the Philippines v. Rezor Juanillo Manzano, Jr. began with a seemingly simple request for cigarettes, escalating into a brutal murder. Rezor Juanillo Manzano, Jr. and his brother, Resurrecion, were accused of fatally stabbing Lucio Silava. Rezor admitted to the killing but claimed self-defense, alleging that Lucio initiated the aggression by throwing stones at his house and later attacking him with a knife. The prosecution, however, presented a different narrative, asserting that the Manzano brothers conspired to kill Lucio in his store. The central legal question was whether Rezor’s actions were justified under the principle of self-defense, or if he was guilty of murder.

The Regional Trial Court (RTC) and the Court of Appeals (CA) both found Rezor guilty of murder, a decision that hinged on the credibility of witnesses and the assessment of evidence. The Supreme Court, in its review, affirmed these findings, emphasizing the principle that the findings of the trial court regarding the credibility of witnesses should be respected, especially when affirmed by the appellate court. The Court noted that it is a general rule in criminal cases that an examination of the entire records of a case may be explored for the purpose of arriving at a correct conclusion. It is for this reason that the Court has painstakingly reviewed the records of this case; yet, it found no reason to depart from the well-entrenched rule that the findings of the RTC as to the credibility of witnesses should not be disturbed considering the absence of any showing that it had overlooked a material fact that otherwise would change the outcome of the case or had misunderstood a circumstance of consequence in their evaluation of the credibility of the witnesses. The testimony of Victoria, Lucio’s spouse, was particularly critical, identifying Rezor and his brother as the assailants. The Court found Victoria’s testimony positive, convincing, and straightforward.

The accused-appellant tried to dent the credibility of Victoria by asserting that she did not actually see the scuffle between him and Lucio as verified by her admission during the cross-examination by the defense. However, the contention of the accused-appellant is without merit. The records bear out that Victoria admitted that right after she heard Lucio utter “What wrong did I commit,” she immediately went to the kitchen and found her husband leaning on the kitchen door, bloodied, while the accused-appellant and Resurrecion were stabbing him. The Supreme Court stated:

It was clear from the testimony of Victoria that she was able to personally witness when the accused-appellant and Resurrecion assaulted Lucio; and that she could not be mistaken as to the assailants’ identity since the place where the crime happened was well-lighted.

Building on this principle of credibility, the Court addressed Rezor’s claim of self-defense. The law dictates that anyone who pleads a justifying circumstance under Article 11 of the Revised Penal Code admits to the commission of acts, which would otherwise engender criminal liability. Self-defense requires the accused to prove that there was an unlawful and unprovoked attack that endangered their life, forcing them to inflict severe wounds upon the assailant. The Supreme Court underscored that self-defense, to be successfully invoked, must be proven by clear and convincing evidence that excludes any vestige of criminal aggression on the part of the person invoking it.

To establish self-defense, Rezor had to demonstrate three critical elements: unlawful aggression on the part of the victim, reasonable necessity of the means employed to prevent or repel such aggression, and lack of sufficient provocation on the part of the person resorting to self-defense. The absence of even one of these elements would invalidate the claim of self-defense. The Court, in its analysis, focused primarily on the element of unlawful aggression, stating:

Unlawful aggression on the part of the victim is the primordial element of the justifying circumstance of self-defense. Without unlawful aggression, there can be no justified killing in defense of oneself.

The Court highlighted that the aggression must put in real peril the life or personal safety of the person defending himself, and the peril must not be an imagined or imaginary threat. The evidence presented by Rezor failed to convince the Court that Lucio initiated an unlawful attack. The prosecution’s evidence, particularly the testimony of Victoria and the physical evidence of blood splatters inside the store, contradicted Rezor’s version of events. Where the physical evidence on record runs counter to the testimonies of witnesses, the primacy of the physical evidence must be upheld. Furthermore, the Court noted that Rezor had neither witness nor evidence to fortify his claim that the unlawful aggression started with Lucio.

It is also important to remember that, a plea of self-defense is controverted by the nature, number, and location of the wounds inflicted on the victim, since the gravity of said wounds is indicative of a determined effort to kill and not just to defend. The postmortem examination revealed that Lucio sustained fifteen wounds, four of which were fatal, indicating an undeniable intent on the part of Rezor to kill. Given these circumstances, the Supreme Court concluded that Rezor’s claim of self-defense was untenable, leading to the determination of the offense committed. The Court then addressed whether the crime was murder or homicide, focusing on the presence of qualifying circumstances such as treachery and abuse of superior strength. To warrant a conviction for the crime of murder, the following essential elements must be present: (a) that a person was killed; (b) that the accused killed him or her; (c) that the killing was attended by any of the qualifying circumstances mentioned in Art. 248 of the RPC; and (d) that the killing is not parricide or infanticide. Treachery is present when the offender commits any of the crimes against a person, employing means, methods, or forms in the execution thereof which tend directly and specially to insure its execution, without risk to himself arising from the defense which the offended party might make.

The Court found that the accused-appellant and Resurrecion deliberately made it appear to Victoria and Lucio on the night of 19 March 2010, that their main purpose in coming to the store was to buy cigarettes. They came at night when neighbors were probably asleep which would make it impossible for them to lend assistance to Lucio. The Court also determined that since treachery qualified the crime to murder, the generic aggravating circumstance of abuse of superior strength is necessarily included in the former. These findings led the Supreme Court to affirm Rezor’s conviction for murder. Finally, the Supreme Court addressed the issue of voluntary surrender as a mitigating circumstance. For voluntary surrender to be appreciated as a mitigating circumstance, the following elements must be present, to wit: (1) the accused has not been actually arrested; (2) the accused surrenders himself to a person in authority or the latter’s agent; and (3) the surrender is voluntary. Records showed that it was Reno who went to the Hamtic police station to request that they take custody of the accused-appellant who was then in his house. Undoubtedly, when the police went to Reno’s house at San Angel, San Jose, Antique, it was for the purpose of arresting the accused-appellant and not because he was surrendering to them voluntarily.

FAQs

What was the key issue in this case?	The key issue was whether Rezor Juanillo Manzano, Jr. acted in self-defense when he stabbed and killed Lucio Silava, or if he was guilty of murder. The court examined the presence of unlawful aggression and other elements of self-defense.
What is unlawful aggression?	Unlawful aggression is a physical or material attack, or an imminent threat thereof, that endangers the life or personal safety of the person defending themselves. This is the most important element in claiming self-defense.
What did the prosecution argue?	The prosecution argued that Rezor and his brother conspired to kill Lucio Silava inside his store. They said the brothers feigned wanting to buy cigarettes to gain entry.
Why did the Supreme Court reject the self-defense claim?	The Supreme Court rejected the self-defense claim because Rezor failed to prove that Lucio committed unlawful aggression against him. The evidence and witness testimony suggested the opposite.
What evidence supported the finding of murder?	The presence of treachery, established by the sudden and unexpected nature of the attack, qualified the killing as murder. The severe wounds inflicted on Lucio also indicated an intent to kill.
Did Rezor’s surrender affect the outcome?	No, the court did not consider Rezor’s surrender as a mitigating circumstance. It was because his surrender was not considered voluntary, as the police were already on their way to arrest him.
What was the final ruling of the Supreme Court?	The Supreme Court affirmed the lower court’s decision, finding Rezor Juanillo Manzano, Jr. guilty of murder and sentencing him to reclusion perpetua. The court also awarded damages to the heirs of Lucio Silava.
What damages were awarded to the victim’s heirs?	The heirs of Lucio Silava were awarded civil indemnity, moral damages, exemplary damages, and temperate damages. The total was P275,000.00, plus interest at a rate of 6% per annum from the finality of the decision until fully paid.

The Supreme Court’s decision in People v. Rezor Juanillo Manzano, Jr. serves as a stark reminder of the stringent requirements for proving self-defense in Philippine law. The ruling reinforces the principle that unlawful aggression is the cornerstone of self-defense claims, and that the burden of proof lies heavily on the accused. This case further clarifies the importance of credible witness testimony and physical evidence in determining the facts of a crime, providing a comprehensive analysis of justifiable self-defense and its limitations.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines, Plaintiff-Appellee, v. Rezor Juanillo Manzano, Jr., Accused-Appellant, G.R. No. 217974, March 05, 2018