In People v. Pajabera, the Supreme Court affirmed the conviction of Roberto Pajabera for murder, highlighting the importance of credible witness testimony and the presence of treachery in determining guilt. The Court emphasized that factual findings of trial courts, especially when affirmed by the appellate court, are given great weight, absent any indication of overlooked or improperly appreciated evidence. This case underscores how self-defense claims must be convincingly proven and how treachery can elevate a killing to murder, significantly impacting the accused’s fate.

Cockfight Brawl or Cold-Blooded Killing? Unpacking Self-Defense and Treachery

The case revolves around the tragic death of Majen B. Bolanos at a cockfighting arena in Camarines Sur. Roberto Pajabera was charged with murder, accused of fatally stabbing Bolanos from behind with a “balisong.” At trial, Pajabera admitted to the stabbing but claimed it was an act of self-defense. According to Pajabera, he and Bolanos had a wager, and when Bolanos refused to pay, he attacked Pajabera with a bladed weapon. The critical question before the court was whether Pajabera acted in self-defense or committed murder with treachery.

The prosecution presented eyewitness accounts from Efren Basi and Ceferino Barcillano, who testified that Pajabera called the victim from behind, placed a hand on his shoulder, and then stabbed him. This sudden and unexpected attack, according to the prosecution, constituted treachery. The defense, however, presented Salvador Habulin, who claimed to have witnessed the incident and corroborated Pajabera’s account of self-defense. Habulin’s testimony, however, contained inconsistencies that ultimately undermined his credibility in the eyes of the court.

The trial court found Pajabera guilty of murder, qualified by treachery. The court rejected Pajabera’s claim of self-defense, finding it improbable that the victim could have been accidentally stabbed in the shoulder given the positions described by Pajabera. The Court of Appeals affirmed this decision, emphasizing Pajabera’s failure to prove self-defense with clear and convincing evidence. Self-defense, under Philippine law, requires the accused to prove unlawful aggression on the part of 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 himself.

The Supreme Court upheld the lower courts’ findings, emphasizing the principle that credibility of witnesses is best determined by the trial court. The Court noted inconsistencies in the testimony of the defense’s eyewitness, Habulin, which cast doubt on his account of the events. These inconsistencies pertained to the respective positions of Pajabera and Bolanos during the alleged struggle, a crucial aspect of the self-defense claim. The Court noted that the defense witness’s version of events changed on cross examination, weakening the defense narrative.

The Court also addressed the issue of treachery, finding that the attack was made swiftly and unexpectedly on an unsuspecting and unarmed victim. The essence of treachery (alevosia) is the sudden and unexpected attack that deprives the victim of any real chance to defend himself, thereby ensuring the commission of the crime without risk to the offender. In this case, the sudden stabbing from behind met the criteria for treachery, thus qualifying the killing as murder. Here’s how the elements played out:

• Suddenness of attack ensured that the victim was rendered defenceless
• Unsuspecting nature of the victim allowed no chance to mount any resistance
• Unarmed victim was no match for the perpetrator’s bladed instrument

With treachery established and absent any mitigating circumstances, the Court affirmed the penalty of reclusion perpetua, which carries the accessory penalty of perpetual absolute disqualification.

Regarding damages, the Court modified the awards, replacing actual damages with temperate damages of P25,000, given that the actual damages proven were less than that amount. Additionally, the Court awarded exemplary damages of P25,000 due to the presence of treachery, an aggravating circumstance. Exemplary damages are awarded in criminal cases when the crime was committed with one or more aggravating circumstances, serving as a deterrent to similar acts in the future.

FAQs

What was the key issue in this case?	The central issue was whether Roberto Pajabera acted in self-defense when he stabbed Majen B. Bolanos, or whether the killing constituted murder qualified by treachery. The court had to determine the credibility of witnesses and assess the circumstances surrounding the incident.
What did the accused claim?	Roberto Pajabera admitted to stabbing Majen B. Bolanos but claimed he did so in self-defense after Bolanos allegedly attacked him first with a bladed weapon. He stated that during a scuffle, the victim was accidentally stabbed with his own weapon.
What is the legal definition of treachery?	Treachery is the deliberate employment of means, methods, or forms in the execution of a crime which ensures its commission without risk to the offender arising from the defense which the offended party might make. The attack must be sudden and unexpected, giving the victim no chance to defend themselves.
Why did the court reject the self-defense claim?	The court found the accused’s version of events improbable, especially concerning how the victim was allegedly accidentally stabbed in the shoulder during the scuffle. The inconsistencies in the defense witness’s testimony further weakened the self-defense claim.
What is the significance of witness credibility in this case?	The case underscores the importance of credible witness testimony in legal proceedings. The Supreme Court gives great weight to the trial court’s assessment of witness credibility, as the trial court has the opportunity to observe the witnesses’ demeanor and assess their truthfulness.
What damages were awarded in this case?	The Court awarded P50,000 as civil indemnity, P50,000 as moral damages, P25,000 as temperate damages (in lieu of actual damages), and P25,000 as exemplary damages. These awards aim to compensate the victim’s heirs for the loss and suffering caused by the crime.
What is the penalty for murder in the Philippines?	Under the Revised Penal Code, murder is punishable by reclusion perpetua to death. The specific penalty depends on the presence of aggravating or mitigating circumstances.
What are exemplary damages?	Exemplary damages are awarded in addition to compensatory damages (like civil indemnity and moral damages) to serve as a deterrent and to punish the offender, especially when the crime is committed with aggravating circumstances like treachery.

The Pajabera case serves as a crucial reminder of the weight courts give to credible witness testimony and the stringent requirements for proving self-defense. The presence of treachery significantly alters the legal landscape, transforming a potential case of homicide into murder, with severe consequences for the accused.

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 v. Roberto Pajabera, G.R. No. 177162, March 31, 2009