In People v. Godofredo Macaraig, the Supreme Court affirmed the conviction of the accused for murder, underscoring the stringent requirements for claiming self-defense. The Court emphasized that when an accused admits to the killing but claims it was done in self-defense, the burden shifts to the accused to prove the elements of self-defense by clear and convincing evidence. Failure to adequately demonstrate unlawful aggression negates the claim of self-defense, resulting in a murder conviction with the corresponding penalties and civil liabilities.

Stab in the Dark: When Self-Defense Claims Fail to Illuminate the Truth

The case revolves around the fatal stabbing of Joven Celeste by Godofredo Macaraig. The prosecution presented evidence indicating that Macaraig approached Celeste from behind and stabbed him without provocation. In contrast, Macaraig claimed that he acted in self-defense after being attacked by unidentified men, one of whom was accidentally stabbed. The trial court and the Court of Appeals both found Macaraig guilty of murder, a decision that hinged significantly on the failure to establish unlawful aggression on the part of the victim.

The central issue in this case is whether Macaraig’s claim of self-defense was substantiated by credible evidence. To successfully invoke self-defense, the accused must demonstrate the presence of three essential elements. These elements are: unlawful aggression, 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 most critical of these is **unlawful aggression**, defined as an actual physical assault or a threat of imminent physical harm to a person. The absence of unlawful aggression effectively invalidates any claim of self-defense. The Supreme Court has consistently held that unlawful aggression must be proven first; without it, self-defense, whether complete or incomplete, cannot be validly claimed.

Macaraig’s defense faltered because his account of the events leading to the stabbing lacked credibility and failed to establish that Celeste initiated any form of aggression against him. His testimony was vague and inconsistent, failing to clearly identify Celeste as an aggressor. The Court noted that Macaraig’s claim that someone else was accidentally stabbed during the alleged attack further undermined his self-defense argument. The Court of Appeals highlighted this inconsistency, stating:

In this case, however, the accused-appellant stated that it was not him who stabbed the victim, but the victim’s companion or somebody else. From this observation alone, the trial court correctly struck down accused-appellant’s (plea) self-defense. As correctly stated by the State in its Comment, this assertion negates accused-appellant’s defense.

The prosecution, on the other hand, presented a compelling case supported by eyewitness testimony and a dying declaration from the victim. Francis Losano testified that Macaraig approached Celeste from behind and stabbed him without warning. Moreover, the victim’s statement to his cousin, Herson Heles, identifying Macaraig as his attacker, was admitted as a dying declaration. According to the Rules of Court, a **dying declaration** is admissible as evidence if it meets specific criteria:

(a) it concerns the cause and the surrounding circumstances of the declarant’s death; (b) it is made when death appears to be imminent and the declarant is under a consciousness of impending death; (c) the declarant would have been competent to testify had he or she survived; and (d) the dying declaration is offered in a case in which the subject of inquiry involves the declarant’s death.

The Supreme Court found that all these requisites were met in this case. Celeste’s statement identifying Macaraig as his assailant, made while being transported to the hospital and shortly before his death, was deemed credible and admissible as evidence. Such declarations are considered highly reliable because a person facing imminent death is unlikely to make false accusations.

The prosecution also successfully established the presence of **treachery**, which qualified the killing as murder. Treachery exists when the offender employs means, methods, or forms in the execution of the crime that tend directly and specially to ensure its execution without risk to himself arising from the defense which the offended party might make. Losano’s testimony indicated that Macaraig’s attack was sudden and unexpected, leaving Celeste with no opportunity to defend himself. The Supreme Court cited Losano’s account:

He was behind him and then when he got near, he put his left arm on Joven’s shoulders and then he stab (sic) Joven using his right arm.

This element of surprise and the deliberate manner of the attack demonstrated that Macaraig employed means to ensure the commission of the crime without any risk to himself.

Given the presence of treachery, the crime was correctly classified as murder, which carries a penalty of reclusion perpetua to death under Article 248 of the Revised Penal Code. The Supreme Court affirmed the lower courts’ imposition of reclusion perpetua, considering the absence of any mitigating or aggravating circumstances. Additionally, the Court addressed the issue of damages, adjusting the amounts awarded to the heirs of the victim to align with prevailing jurisprudence. Specifically, the moral damages were increased from PhP50,000 to PhP75,000, and the exemplary damages were increased from PhP30,000 to PhP75,000. All damages awarded were made subject to a legal interest rate of six percent (6%) per annum from the date of the judgment’s finality until fully paid.

FAQs

What was the key issue in this case?	The key issue was whether the accused, Godofredo Macaraig, could validly claim self-defense in the fatal stabbing of Joven Celeste, and whether the prosecution proved his guilt of murder beyond reasonable doubt. The court focused on determining if unlawful aggression, a necessary element for self-defense, was present.
What is unlawful aggression?	Unlawful aggression is defined as an actual physical assault, or at least a threat to inflict real imminent injury, upon a person. It is the most critical element in self-defense, as self-defense cannot be claimed without it.
What is a dying declaration, and why is it important in this case?	A dying declaration is a statement made by a person who is about to die, concerning the cause and circumstances of their death. In this case, Joven Celeste’s identification of Macaraig as his attacker was admitted as a dying declaration, providing strong evidence against the accused.
What is treachery, and how did it affect the outcome of the case?	Treachery is the employment of means, methods, or forms in the execution of a crime that ensure its commission without risk to the offender. The court found that Macaraig employed treachery by attacking Celeste from behind, which qualified the killing as murder.
What damages were awarded to the victim’s heirs?	The heirs of Joven Celeste were awarded PhP75,000 as civil indemnity, PhP75,000 as moral damages, PhP16,750 as actual damages, and PhP75,000 as exemplary damages. These damages aim to compensate the family for their loss and to set an example to deter similar crimes.
What does it mean to be convicted of murder?	A conviction for murder means the accused is found guilty of unlawfully killing another person with malice aforethought, often characterized by treachery or other qualifying circumstances. The penalty for murder under the Revised Penal Code is reclusion perpetua to death.
Why did Macaraig’s claim of self-defense fail?	Macaraig’s self-defense claim failed because he did not provide credible evidence that Joven Celeste initiated any unlawful aggression against him. His testimony was inconsistent, and he could not clearly establish that Celeste posed an imminent threat.
What is the significance of shifting the burden of proof in self-defense cases?	When an accused admits to the killing but claims self-defense, the burden of proof shifts from the prosecution to the defense. This means the accused must then provide clear and convincing evidence to support their claim of self-defense, rather than the prosecution having to disprove it.

In conclusion, People v. Godofredo Macaraig serves as a crucial reminder of the stringent requirements for successfully claiming self-defense, particularly the necessity of proving unlawful aggression. The decision underscores the importance of credible evidence and consistent testimony when asserting such a defense in criminal proceedings. The case also highlights the impact of dying declarations and the role of treachery in elevating a killing to the crime of murder.

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. Godofredo Macaraig y Gonzales, G.R. No. 219848, June 07, 2017