G.R. No. 157804 ; June 20, 2006
CERILO BRICENIO, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Cerilo Bricenio was charged with homicide for the death of Roy Rivera. The prosecution evidence established that on March 12, 1992, Rivera, who was intoxicated, accidentally bumped into Bricenio at Jaime’s Fastfood Restaurant in Baguio City. Despite an immediate apology from Rivera’s companion, Bricenio allegedly pulled Rivera inside, picked up a wooden stool, and struck Rivera’s head twice, causing fatal injuries. Prosecution witnesses Renato Concepcion and Danny Singson corroborated this account, stating that a bottle-throwing melee ensued between Rivera’s group and Bricenio’s companions, after which Rivera was found gravely injured.
The defense presented a contrary version. Bricenio testified that he was a bystander who tried to pacify a fight initiated by Rivera’s group against his fellow security guards. He claimed it was his companions, Armando Tualla and Bernabe Foronda, who struck Rivera with a bottle and a stool. He asserted he merely used a stool to shield himself from bottles and later helped bring Rivera to the hospital. The trial court and the Court of Appeals found the prosecution’s version credible and convicted Bricenio of homicide.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of petitioner Cerilo Bricenio for homicide.

RULING

The Supreme Court denied the petition and affirmed the conviction. The Court emphasized that factual findings of the trial court, especially when affirmed by the Court of Appeals, are generally binding and conclusive. It found no reason to deviate from this rule, as the assessment of witness credibility by the lower courts was sound. The prosecution witnesses provided a clear, consistent, and credible narrative identifying Bricenio as the direct assailant who struck the victim with a stool. Their testimonies were deemed more trustworthy than the defense’s claim, which was largely uncorroborated.
The Court rejected Bricenio’s defenses. His claim of acting in self-defense or in defense of strangers was untenable as he failed to prove unlawful aggression, a requisite element. The accidental bump by the intoxicated victim did not constitute an imminent threat justifying a violent response. His act of bringing the victim to the hospital was not proof of innocence but could have been motivated by other reasons. Furthermore, his offer to compromise the case during the appeal was an implied admission of guilt under the Rules of Court. The award of damages was modified, reducing moral damages to P50,000 in line with prevailing jurisprudence.