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GR No. 181052

2012-11-14

PERALTA, J.

Be that as it may, the CA need have discussed in its decision the presence of a dying declaration or a statement as part of the res gestae, because petitioner Rodolfo admitted stabbing the victim but insists that he had done the deed to defend himself. It is settled that when an accused admits killing the victim but invokes self-defense to escape criminal liability, the accused assumes the burden to establish his plea by credible, clear and convincing evidence; otherwise, conviction would follow from his admission that he killed the victim.[15] Self-defense cannot be justifiably appreciated when uncorroborated by independent and competent evidence or when it is extremely doubtful by itself.[16] Indeed, in invoking self-defense, the burden of evidence is shifted and the accused claiming self-defense must rely on the strength of his own evidence and not on the weakness of the prosecution.[17]

GR No. 183092

2011-05-30

PEOPLE v. ANTONIO SABELLA Y BRAGAIS

BRION, J.

When an accused admits killing the victim but invokes self-defense to escape criminal liability, the accused assumes the burden to establish his plea by credible, clear and convincing evidence; otherwise, conviction would follow from his admission that he killed the victim.[18]

GR No. 181594

2008-08-28

PEOPLE v. ROLLY FLORA Y CANDELARIA

CHICO-NAZARIO, J.

In criminal law, it is settled that when the killing is admitted and self-defense is invoked, the burden of evidence shifts to the accused to show that the result (killing) was legally justified. Otherwise stated, the accused assumes the burden to establish his plea by credible, clear and convincing evidence; otherwise, conviction would follow from his admission that he killed the victim.[39] In the case at bar, having owned up to the killing of the victim, the accused should be able to prove the elements of self-defense in order to avail himself of this justifying circumstance; and he must discharge this burden by clear and convincing evidence.

GR No. 173282

2008-03-04

JOSE INGAL y SANTOS v. PEOPLE

CHICO-NAZARIO, J.

The information alleged that petitioner, together with Ricardo Lidot and others whose names are still unknown, conspired in killing Rolando Domingo. Article 8 of the Revised Penal Code provides that there is conspiracy when two or more persons agree to commit a crime and decide to commit it. It is hornbook doctrine that conspiracy must be proved by positive and convincing evidence, the same quantum of evidence as the crime itself.[56] Once conspiracy is established, all the conspirators are answerable as co-principals regardless of their degree of participation, for in the contemplation of the law, the act of one becomes the act of all, and it matters not who among the accused inflicted the fatal blow to the victim.[57]

GR No. 177294

2008-02-19

PEOPLE v. JOSEPH DELA PAZ

CHICO-NAZARIO, J.

Jurisprudence holds that denial, like alibi, is inherently weak and crumbles in the light of positive declarations of truthful witnesses who testified on affirmative matters that appellant was at the scene of the crime and was the victim's assailant. To merit credibility, it must be buttressed by strong evidence of non-culpability. Also, being a negative defense, denial must be substantiated by clear and convincing evidence; otherwise, it would merit no weight in law and cannot be given greater evidentiary value than the testimony of credible witnesses who testified on affirmative matters.[39]

GR No. 127980

2007-12-19

DE LA SALLE UNIVERSITY v. CA

REYES, R.T., J.

Courts reject alibi when there are credible eyewitnesses to the crime who can positively identify the accused.[82] Alibi is an inherently weak defense and courts must receive it with caution because one can easily fabricate an alibi.[83] Jurisprudence holds that denial, like alibi, is inherently weak and crumbles in light of positive declarations of truthful witnesses who testified on affirmative matters that accused were at the scene of the crime and were the victim's assailants. As between categorical testimonies that ring of truth on one hand and a bare denial on the other, the former must prevail.[84] Alibi is the weakest of all defenses for it is easy to fabricate and difficult to disprove, and it is for this reason that it cannot prevail over the positive identification of accused by the witnesses.[85]

GR NO. 177746

2007-08-31

PEOPLE v. ARTURO BARLAAN Y ABION

YNARES-SANTIAGO, J.

The issue raised in this appeal, i.e., whether or not the accused participated in the commission of the crime by holding the legs of the victim, is factual in nature. Settled is the rule that this Court is not a trier of facts. Factual findings of the lower courts are accorded great weight and respect and are deemed final, moreso in this case where the appellate court affirmed the factual findings of the trial court. Admittedly, there are exceptions to this rule, such as when the trial court ignored, misconstrued or misinterpreted facts and circumstances of substance which, if considered, would alter the outcome of the case.[7] However, none is present in the instant case. At any rate, we reviewed the findings of the trial court and the Court of Appeals and found the same to be duly supported by the records. Besides, as between categorical testimonies that ring of truth on one hand and a bare denial on the other, this Court has strongly ruled that the former must prevail. Indeed, positive identification of the appellants when categorical and consistent and without any ill-motive on the part of the eyewitnesses testifying on the matter, prevails over alibi and denial.[8]

GR NO. 175881

2007-08-28

PEOPLE v. ARMANDO RODAS

CHICO-NAZARIO, J.

The information alleged that appellants, together with Charlito and Jose Jr., conspired in killing Titing Asenda. Article 8 of the Revised Penal Code provides that there is conspiracy when two or more persons agree to commit a crime and decide to commit it. It is hornbook doctrine that conspiracy must be proved by positive and convincing evidence, the same quantum of evidence as the crime itself.[41] Indeed, proof of previous agreement among the malefactors to commit the crime is not essential to prove conspiracy. It is not necessary to show that all the conspirators actually hit and killed the victim; what is primordial is that all the participants performed specific acts with such closeness and coordination as to indicate a common purpose or design to bring about the victim's death.[42] Once conspiracy is established, all the conspirators are answerable as co-principals regardless of their degree of participation. In the contemplation of the law, the act of one becomes the act of all, and it matters not who among the accused inflicted the fatal blow on the victim.[43]

GR NO. 158053

2007-06-21

EDWIN RAZON Y LUCEA v. PEOPLE

AUSTRIA-MARTINEZ, J.

It is settled that when an accused admits killing the victim but invokes self-defense to escape criminal liability, the accused assumes the burden to establish his plea by credible, clear and convincing evidence; otherwise, conviction would follow from his admission that he killed the victim.[38] Self-defense cannot be justifiably appreciated when uncorroborated by independent and competent evidence or when it is extremely doubtful by itself.[39] Indeed, in invoking self-defense, the burden of evidence is shifted and the accused claiming self-defense must rely on the strength of his own evidence and not on the weakness of the prosecution.[40]

GR NO. 168827

2007-04-13

BENJAMIN P. MARTINEZ v. CA

CALLEJO, SR., J.

Aggression, if not continuous, does not constitute aggression warranting self-defense.[53] When unlawful aggression ceases, the defender no longer has any justification to kill or wound the original aggressor. The assailant is no longer acting in self-defense but in retaliation against the original aggressor.[54]

GR NO. 159950

2007-02-12

JOEL P. GONZALES v. PEOPLE

QUISUMBING, J.

Now, temperate damages may be recovered when the court finds that some pecuniary loss has been suffered but its amount cannot from the nature of the case be proved with certainty.[15] Under the circumstances, we find it reasonable to award Canlas with P500,000 temperate damages, and to the other complaining witnesses, Simpao and Villaflor, the amount of P100,000 as temperate damages each. In addition, exemplary or corrective damages should be awarded as a way to emphasize that any future conduct of this nature is condemned so as to correct the anti-social behavior that is deleterious in its consequences.[16] Thus, Canlas and the other complaining witnesses, Simpao and Villaflor, should be awarded P50,000 each as exemplary damages.

GR NO. 169246

2007-01-26

PEOPLE v. NICOLAS GUZMAN Y BOCBOSILA

CHICO-NAZARIO, J.

With regard to the allegation in the Information that the killing of Michael was attended by an aggravating circumstance of evident premeditation, the RTC and the Court of Appeals were correct in disregarding the same against appellant. The essence of evident premeditation as an aggravating circumstance is that the execution of the criminal act was preceded by cool thought and reflection upon the resolution to carry out the criminal intent during a space of time sufficient to arrive at a calm judgment.[42] It implies a deliberate planning of the crime before executing it. It must also be shown how and when the plan to kill was hatched or what time elapsed before it was carried out.[43] Further, there must be proof that the accused meditated and reflected on his intention between the time when the crime was conceived by him and the time it was actually perpetrated.[44] In the case at bar, there is no evidence to show that appellant and his two companions had previously planned and reflected in killing Michael. When appellant and his two companions saw Michael on that fateful night, they immediately pounced on him. The thought of killing Michael came into the minds of appellant and his two companions only when they saw Michael walking on the road. Indeed, the killing of Michael was sudden and unplanned.

GR NO. 166479

2006-02-28

RODOLFO C. VELASCO v. PEOPLE

CHICO-NAZARIO, J.

This argument does not inspire belief. The blood relationship of Armando Maramba and private complainant would not render the former's testimony unworthy of belief. On the contrary, relationship could strengthen the witnesses' credibility, for it is unnatural for an aggrieved relative to falsely accuse someone other than the actual culprit. Their natural interest in securing the conviction of the guilty would deter them from implicating a person other than the true offender.[42] It is settled that where there is no evidence and nothing to indicate that the principal witnesses for the prosecution were actuated by improper motive, the presumption is that they were not so actuated and their testimonies are entitled to full faith and credit.[43] The weight of the testimony of witnesses is not impaired nor in anyway affected by their relationship to the victim when there is no showing of improper motive on their part.[44] Jurisprudence likewise holds that if an accused had really nothing to do with a crime, it would be against the natural order of events and of human nature, and against the presumption of good faith, that a prosecution witness would falsely testify against him.[45] In the case before us, aside from petitioner's claim that he was framed-up, there is nothing in the records that shows that Armando Maramba had ulterior motives in testifying against him. Necessarily, the testimony of Armando Maramba must be given full credit.

	GR No. 181052 2012-11-14	RODOLFO BELBIS v. PEOPLE PERALTA, J.
Be that as it may, the CA need have discussed in its decision the presence of a dying declaration or a statement as part of the res gestae, because petitioner Rodolfo admitted stabbing the victim but insists that he had done the deed to defend himself. It is settled that when an accused admits killing the victim but invokes self-defense to escape criminal liability, the accused assumes the burden to establish his plea by credible, clear and convincing evidence; otherwise, conviction would follow from his admission that he killed the victim.[15] Self-defense cannot be justifiably appreciated when uncorroborated by independent and competent evidence or when it is extremely doubtful by itself.[16] Indeed, in invoking self-defense, the burden of evidence is shifted and the accused claiming self-defense must rely on the strength of his own evidence and not on the weakness of the prosecution.[17]
	GR No. 183092 2011-05-30	PEOPLE v. ANTONIO SABELLA Y BRAGAIS BRION, J.
When an accused admits killing the victim but invokes self-defense to escape criminal liability, the accused assumes the burden to establish his plea by credible, clear and convincing evidence; otherwise, conviction would follow from his admission that he killed the victim.[18]
	GR No. 181594 2008-08-28	PEOPLE v. ROLLY FLORA Y CANDELARIA CHICO-NAZARIO, J.
In criminal law, it is settled that when the killing is admitted and self-defense is invoked, the burden of evidence shifts to the accused to show that the result (killing) was legally justified. Otherwise stated, the accused assumes the burden to establish his plea by credible, clear and convincing evidence; otherwise, conviction would follow from his admission that he killed the victim.[39] In the case at bar, having owned up to the killing of the victim, the accused should be able to prove the elements of self-defense in order to avail himself of this justifying circumstance; and he must discharge this burden by clear and convincing evidence.
	GR No. 173282 2008-03-04	JOSE INGAL y SANTOS v. PEOPLE CHICO-NAZARIO, J.
The information alleged that petitioner, together with Ricardo Lidot and others whose names are still unknown, conspired in killing Rolando Domingo. Article 8 of the Revised Penal Code provides that there is conspiracy when two or more persons agree to commit a crime and decide to commit it. It is hornbook doctrine that conspiracy must be proved by positive and convincing evidence, the same quantum of evidence as the crime itself.[56] Once conspiracy is established, all the conspirators are answerable as co-principals regardless of their degree of participation, for in the contemplation of the law, the act of one becomes the act of all, and it matters not who among the accused inflicted the fatal blow to the victim.[57]
	GR No. 177294 2008-02-19	PEOPLE v. JOSEPH DELA PAZ CHICO-NAZARIO, J.
Jurisprudence holds that denial, like alibi, is inherently weak and crumbles in the light of positive declarations of truthful witnesses who testified on affirmative matters that appellant was at the scene of the crime and was the victim's assailant. To merit credibility, it must be buttressed by strong evidence of non-culpability. Also, being a negative defense, denial must be substantiated by clear and convincing evidence; otherwise, it would merit no weight in law and cannot be given greater evidentiary value than the testimony of credible witnesses who testified on affirmative matters.[39]
	GR No. 127980 2007-12-19	DE LA SALLE UNIVERSITY v. CA REYES, R.T., J.
Courts reject alibi when there are credible eyewitnesses to the crime who can positively identify the accused.[82] Alibi is an inherently weak defense and courts must receive it with caution because one can easily fabricate an alibi.[83] Jurisprudence holds that denial, like alibi, is inherently weak and crumbles in light of positive declarations of truthful witnesses who testified on affirmative matters that accused were at the scene of the crime and were the victim's assailants. As between categorical testimonies that ring of truth on one hand and a bare denial on the other, the former must prevail.[84] Alibi is the weakest of all defenses for it is easy to fabricate and difficult to disprove, and it is for this reason that it cannot prevail over the positive identification of accused by the witnesses.[85]
	GR NO. 177746 2007-08-31	PEOPLE v. ARTURO BARLAAN Y ABION YNARES-SANTIAGO, J.
The issue raised in this appeal, i.e., whether or not the accused participated in the commission of the crime by holding the legs of the victim, is factual in nature. Settled is the rule that this Court is not a trier of facts. Factual findings of the lower courts are accorded great weight and respect and are deemed final, moreso in this case where the appellate court affirmed the factual findings of the trial court. Admittedly, there are exceptions to this rule, such as when the trial court ignored, misconstrued or misinterpreted facts and circumstances of substance which, if considered, would alter the outcome of the case.[7] However, none is present in the instant case. At any rate, we reviewed the findings of the trial court and the Court of Appeals and found the same to be duly supported by the records. Besides, as between categorical testimonies that ring of truth on one hand and a bare denial on the other, this Court has strongly ruled that the former must prevail. Indeed, positive identification of the appellants when categorical and consistent and without any ill-motive on the part of the eyewitnesses testifying on the matter, prevails over alibi and denial.[8]
	GR NO. 175881 2007-08-28	PEOPLE v. ARMANDO RODAS CHICO-NAZARIO, J.
The information alleged that appellants, together with Charlito and Jose Jr., conspired in killing Titing Asenda. Article 8 of the Revised Penal Code provides that there is conspiracy when two or more persons agree to commit a crime and decide to commit it. It is hornbook doctrine that conspiracy must be proved by positive and convincing evidence, the same quantum of evidence as the crime itself.[41] Indeed, proof of previous agreement among the malefactors to commit the crime is not essential to prove conspiracy. It is not necessary to show that all the conspirators actually hit and killed the victim; what is primordial is that all the participants performed specific acts with such closeness and coordination as to indicate a common purpose or design to bring about the victim's death.[42] Once conspiracy is established, all the conspirators are answerable as co-principals regardless of their degree of participation. In the contemplation of the law, the act of one becomes the act of all, and it matters not who among the accused inflicted the fatal blow on the victim.[43]
	GR NO. 158053 2007-06-21	EDWIN RAZON Y LUCEA v. PEOPLE AUSTRIA-MARTINEZ, J.
It is settled that when an accused admits killing the victim but invokes self-defense to escape criminal liability, the accused assumes the burden to establish his plea by credible, clear and convincing evidence; otherwise, conviction would follow from his admission that he killed the victim.[38] Self-defense cannot be justifiably appreciated when uncorroborated by independent and competent evidence or when it is extremely doubtful by itself.[39] Indeed, in invoking self-defense, the burden of evidence is shifted and the accused claiming self-defense must rely on the strength of his own evidence and not on the weakness of the prosecution.[40]
	GR NO. 168827 2007-04-13	BENJAMIN P. MARTINEZ v. CA CALLEJO, SR., J.
Aggression, if not continuous, does not constitute aggression warranting self-defense.[53] When unlawful aggression ceases, the defender no longer has any justification to kill or wound the original aggressor. The assailant is no longer acting in self-defense but in retaliation against the original aggressor.[54]
	GR NO. 159950 2007-02-12	JOEL P. GONZALES v. PEOPLE QUISUMBING, J.
Now, temperate damages may be recovered when the court finds that some pecuniary loss has been suffered but its amount cannot from the nature of the case be proved with certainty.[15] Under the circumstances, we find it reasonable to award Canlas with P500,000 temperate damages, and to the other complaining witnesses, Simpao and Villaflor, the amount of P100,000 as temperate damages each. In addition, exemplary or corrective damages should be awarded as a way to emphasize that any future conduct of this nature is condemned so as to correct the anti-social behavior that is deleterious in its consequences.[16] Thus, Canlas and the other complaining witnesses, Simpao and Villaflor, should be awarded P50,000 each as exemplary damages.
	GR NO. 169246 2007-01-26	PEOPLE v. NICOLAS GUZMAN Y BOCBOSILA CHICO-NAZARIO, J.
With regard to the allegation in the Information that the killing of Michael was attended by an aggravating circumstance of evident premeditation, the RTC and the Court of Appeals were correct in disregarding the same against appellant. The essence of evident premeditation as an aggravating circumstance is that the execution of the criminal act was preceded by cool thought and reflection upon the resolution to carry out the criminal intent during a space of time sufficient to arrive at a calm judgment.[42] It implies a deliberate planning of the crime before executing it. It must also be shown how and when the plan to kill was hatched or what time elapsed before it was carried out.[43] Further, there must be proof that the accused meditated and reflected on his intention between the time when the crime was conceived by him and the time it was actually perpetrated.[44] In the case at bar, there is no evidence to show that appellant and his two companions had previously planned and reflected in killing Michael. When appellant and his two companions saw Michael on that fateful night, they immediately pounced on him. The thought of killing Michael came into the minds of appellant and his two companions only when they saw Michael walking on the road. Indeed, the killing of Michael was sudden and unplanned.
	GR NO. 166479 2006-02-28	RODOLFO C. VELASCO v. PEOPLE CHICO-NAZARIO, J.
This argument does not inspire belief. The blood relationship of Armando Maramba and private complainant would not render the former's testimony unworthy of belief. On the contrary, relationship could strengthen the witnesses' credibility, for it is unnatural for an aggrieved relative to falsely accuse someone other than the actual culprit. Their natural interest in securing the conviction of the guilty would deter them from implicating a person other than the true offender.[42] It is settled that where there is no evidence and nothing to indicate that the principal witnesses for the prosecution were actuated by improper motive, the presumption is that they were not so actuated and their testimonies are entitled to full faith and credit.[43] The weight of the testimony of witnesses is not impaired nor in anyway affected by their relationship to the victim when there is no showing of improper motive on their part.[44] Jurisprudence likewise holds that if an accused had really nothing to do with a crime, it would be against the natural order of events and of human nature, and against the presumption of good faith, that a prosecution witness would falsely testify against him.[45] In the case before us, aside from petitioner's claim that he was framed-up, there is nothing in the records that shows that Armando Maramba had ulterior motives in testifying against him. Necessarily, the testimony of Armando Maramba must be given full credit.

PEOPLE v. PAUL TAGANA