G.R. No. 195665 ; September 14, 2011.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. DAVID MANINGDING, Accused-Appellant.

FACTS

The accused, David Maningding, was charged with Murder for stabbing Marlon Muyalde on September 13, 2006, in Barangay Anolid, Mangaldan, Pangasinan. The Information alleged the killing was committed with treachery. During arraignment, the accused pleaded not guilty.
The prosecution presented four witnesses. Aladino Jorge, owner of a sari-sari store, testified that at around 10:25 p.m., he saw the accused arrive. The victim, Marlon, greeted the accused, but the accused remained silent, suddenly raised Marlon’s right hand, and stabbed him in the armpit with a knife. Aladino was about one meter away. Dr. Virgilio De Guzman, who conducted the autopsy, testified the victim died of hypovolemic shock from a single, fatal stab wound that penetrated the diaphragm and liver, about 14 inches deep, caused by a sharp pointed object. Rommel Muyalde, the victim’s brother, corroborated Aladino’s account, stating that after he and Marlon greeted the accused, the accused grabbed Marlon’s right hand, raised it, and stabbed him with his left hand before fleeing. Gloria Muyalde, the victim’s wife, testified on the civil damages, stating the victim was a farmer and bottle trader, and they incurred burial expenses.
The defense presented only the accused, who claimed self-defense. He testified that on his way home, he saw the victim drinking with others. The victim invited him for a drink and then embraced him. The accused claimed he noticed the victim pulling a knife from his waist, which he was able to grab. During a struggle where they fell, he did not know he had stabbed the victim. Upon seeing blood, he ran away out of fear.
The Regional Trial Court (RTC) convicted the accused of Murder, sentencing him to reclusion perpetua and ordering him to pay civil indemnity, actual damages, and moral damages. The RTC gave credence to the eyewitness accounts, found that the accused’s flight negated self-defense, and ruled that treachery attended the killing as the attack was sudden and unexpected. The Court of Appeals affirmed the RTC decision in toto.

ISSUE

Whether the RTC erred in convicting the accused-appellant of Murder, particularly in rejecting his claim of self-defense.

RULING

The Supreme Court sustained the conviction. The Court ruled that the factual determinations of the RTC, affirmed by the CA, are entitled to great weight and finality, as there was no showing that the trial court overlooked or misinterpreted material facts. The claim of self-defense failed because the accused failed to prove the essential element of unlawful aggression on the part of the victim. The positive, clear, and consistent testimonies of the prosecution eyewitnesses, Aladino Jorge and Rommel Muyalde, who had no motive to falsely testify, established that the accused initiated the sudden and unprovoked attack. Their testimonies were more credible than the accused’s uncorroborated version. The Court found no reason to deviate from the lower courts’ findings. The presence of treachery was also affirmed, as the mode of attack, executed suddenly without warning, ensured the victim’s defenselessness. The penalty of reclusion perpetua and the awarded damages were upheld.