In People of the Philippines vs. Alex Flores y Lopez, the Supreme Court clarified the stringent standards for proving self-defense in criminal cases. The Court affirmed that when an accused admits to a killing but claims it was done in self-defense, the burden shifts to the accused to prove the elements of self-defense with clear and convincing evidence. This includes demonstrating unlawful aggression by the victim, reasonable necessity of the means used to prevent the attack, and lack of sufficient provocation by the accused. The Court emphasized that inconsistencies in the accused’s testimony and actions inconsistent with self-defense, such as fleeing the scene, can undermine the credibility of the claim, leading to a conviction for homicide or attempted homicide.

From Worksite Brawl to Homicide Charges: Can Self-Defense Hold Up?

This case revolves around an altercation at a construction site where Alex Flores y Lopez, the appellant, was accused of attempted murder and murder of his co-workers, Gery and Sony Quezon. The incident occurred while the victims were sleeping. Alex Flores claimed self-defense, asserting that the Quezon brothers attacked him first, leading him to use a knife to protect himself. The Regional Trial Court (RTC) convicted Flores of attempted murder for the injuries inflicted on Gery Quezon and murder for the death of Sony Quezon. Dissatisfied with the RTC’s decision, Flores appealed to the Supreme Court, challenging the trial court’s assessment of the evidence and its rejection of his self-defense plea.

The Supreme Court addressed whether the appellant successfully established the elements of self-defense. According to settled jurisprudence, self-defense, when invoked, requires the accused to prove its elements clearly and convincingly. As the Court stated in People v. Rabanal:

If the accused invokes self-defense, the burden of evidence is shifted on him, to prove with clear and convincing evidence, the confluence of the following essential elements: (a) unlawful aggression; (b) 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. The accused must rely on the strength of his own evidence and not on the weakness of the prosecution’s evidence, because having admitted the killing, the testimony of the witnesses of the prosecution can no longer be disbelieved.

The Court scrutinized the evidence presented by the appellant. The appellant’s actions immediately after the incident significantly undermined his claim of self-defense. Specifically, the Court highlighted that:

After stabbing the victims, the appellant fled from the situs criminis to the Baliwag Transit Terminal where the policemen arrested him. The appellant threw the knife he used to stab the victims towards the direction of the gate of the building under construction. He did not proceed to the police station to surrender to the police authorities and report that he stabbed the victims in self-defense. The appellant’s flight from the situs criminis and his failure to surrender himself and the knife he used to kill the victims belie his plea of self-defense.

Furthermore, the Court noted several inconsistencies in the appellant’s testimony. His changing accounts of who attacked him and where he sustained injuries cast doubt on his credibility. The medical evidence presented also contradicted his claims, showing only one laceration on his left cheek, despite his claims of being hit multiple times with pieces of wood.

The Court also found the trial court erred in appreciating treachery against the appellant. Treachery requires proof beyond reasonable doubt that the accused made preparations to kill the victim in a manner that ensures the crime’s completion or makes it difficult for the victim to defend themselves. In this case, the primary witness, Gery Quezon, admitted that he did not see the appellant stab his brother, Sony Quezon. Absent any particulars as to how the attack commenced, treachery could not be established, as the Court pointed out citing several precedents:

A killing at the spur of the moment is not treacherous. Treachery cannot be appreciated against the accused when the witness did not see the commencement of the assault. Absent any particulars as to the manner in which the aggression commenced, treachery cannot be considered.

In light of these findings, the Supreme Court re-evaluated the charges against the appellant. While rejecting the claim of self-defense, the Court also dismissed the finding of treachery. Consequently, the Court found the appellant guilty beyond reasonable doubt of homicide for the death of Sony Quezon and attempted homicide for the injuries inflicted on Gery Quezon. This adjustment reflected the absence of treachery but maintained the conviction for the unlawful killing and attempted killing.

The Court also addressed the trial court’s appreciation of the mitigating circumstance of voluntary surrender. The Court clarified that:

To be entitled to the mitigating circumstance of voluntary surrender, the same must be shown to have been spontaneous and made in such a manner that it shows the intent of the accused to surrender unconditionally to the authorities, either because he acknowledges his guilt or he wishes to save them the trouble and expense that will be incurred in his search and capture.

Given that the appellant was apprehended while attempting to board a bus after fleeing the scene, the Court ruled that he did not voluntarily surrender. This meant that the appellant was not entitled to a reduced penalty based on voluntary surrender.

The Supreme Court adjusted the penalties imposed on the appellant to align with the revised charges. For the crime of homicide, the Court imposed an indeterminate penalty ranging from ten years of prision mayor to fifteen years and six months of reclusion temporal. For attempted homicide, the Court imposed an indeterminate penalty ranging from five months and one day of arresto mayor to two years, four months, and one day of prision correccional. These penalties reflected the absence of modifying circumstances and were consistent with the provisions of the Revised Penal Code.

Additionally, the Court addressed the issue of civil liabilities. While the trial court did not award moral damages to Gery Quezon, the victim of attempted homicide, the Supreme Court rectified this oversight. Citing Article 2219 of the New Civil Code, the Court recognized that Gery Quezon was entitled to moral damages due to the physical injuries he sustained. As such, the Court awarded him P10,000.00 in moral damages. Similarly, the Court awarded temperate damages of P25,000.00 to the heirs of Sony Quezon, acknowledging the pecuniary loss suffered despite the lack of proof of actual damages.

FAQs

What was the key issue in this case?	The key issue was whether the appellant, Alex Flores, acted in self-defense when he stabbed the victims, Sony and Gery Quezon, and whether the prosecution proved treachery to qualify the killing as murder.
What is required to prove self-defense in the Philippines?	To successfully claim self-defense, the accused must prove unlawful aggression by the victim, reasonable necessity of the means employed to prevent or repel it, and lack of sufficient provocation on the part of the person defending themselves.
Why was the appellant’s claim of self-defense rejected?	The appellant’s claim was rejected due to inconsistencies in his testimony, his flight from the crime scene, and the lack of evidence supporting his claim that the victims attacked him with pieces of wood.
What is the significance of fleeing the crime scene?	Fleeing the crime scene is generally seen as an indication of guilt and undermines a claim of self-defense, as it suggests an intent to avoid responsibility rather than a justified act of protection.
What does treachery mean in the context of murder?	Treachery means that the offender employed means, methods, or forms in the execution of the crime that tended directly and specially to ensure its execution, without risk to themselves arising from the defense which the offended party might make.
Why was the finding of treachery overturned?	The finding of treachery was overturned because the witness did not see the commencement of the assault, and there was no clear evidence showing that the appellant consciously adopted a method to ensure the killing without risk to himself.
What is the difference between homicide and murder in this case?	The key difference is the absence of treachery. The initial charge was murder because it alleged treachery, but since treachery was not proven, the conviction was reduced to homicide, which is the unlawful killing of a person without any qualifying circumstances.
What civil liabilities did the appellant incur?	The appellant was ordered to pay P25,000 as temperate damages to the heirs of Sony Quezon for the pecuniary loss suffered due to his death and P10,000 as moral damages to Gery Quezon for the physical injuries he sustained.

The Supreme Court’s decision underscores the importance of credible and consistent evidence when claiming self-defense. It also clarifies the distinctions between murder, homicide, and attempted homicide, emphasizing the necessity of proving qualifying circumstances like treachery beyond reasonable doubt. This case illustrates how inconsistencies and actions contrary to self-preservation can lead to a conviction for a lesser, but still serious, offense.

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, vs. Alex Flores y Lopez, G.R. Nos. 143435-36, November 28, 2003