G.R. No. 271154 , February 24, 2025
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, vs. FRANCIS PATRICIO Y TORDA @ “KIKO,” ACCUSED-APPELLANT.

FACTS

Accused-appellant Francis Patricio, together with Nicholas Dimagiba and Don Diego Pastrana, was charged with Murder for the death of Jeffrey De Castro on November 13, 2015, in Quezon City. The Information alleged that they conspired and attacked Jeffrey with treachery, stabbing him multiple times. Francis surrendered in 2018, pleaded not guilty, and stood trial. Nicholas remains at large. The prosecution presented witnesses, including Jeffrey’s sister Jennifer and neighbor Roy Espinosa. Jennifer testified that around 3:00 a.m., she saw Francis stabbing Jeffrey while Nicholas and Diego held him. Roy testified he witnessed the stabbing, heard Jeffrey say “Bakit ako?,” and saw Francis continue stabbing Jeffrey as he crawled before falling into a river. The medico-legal officer testified Jeffrey sustained 14 stab wounds, nine of which were fatal. The defense, through Francis’s testimony, claimed self-defense. Francis alleged that Jeffrey punched him during an argument, threatened to kill him, and pulled a knife. Francis claimed he grappled for the knife, snatched it, and stabbed Jeffrey in fear for his life. He admitted on cross-examination that he made sure Jeffrey was dead before leaving. The Regional Trial Court convicted Francis of Murder, finding treachery and conspiracy, and rejected his claim of self-defense. The Court of Appeals affirmed the conviction with modification. Francis appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals correctly affirmed accused-appellant Francis Patricio’s conviction for the crime of Murder.

RULING

Yes, the Supreme Court affirmed the conviction for Murder. The Court found that the prosecution proved all elements of Murder under Article 248 of the Revised Penal Code beyond reasonable doubt. The qualifying circumstance of treachery was present, as the attack was sudden and unexpected, rendering Jeffrey defenseless. The testimonies of eyewitnesses Jennifer and Roy were credible and consistent, establishing that Francis repeatedly stabbed Jeffrey while the latter was held by his co-accused and even as he crawled on the ground. The claim of self-defense failed because Francis failed to prove unlawful aggression on Jeffrey’s part. His testimony was uncorroborated and inconsistent with the physical evidence and the number and severity of wounds inflicted. The number, location, and proximity of the stab wounds indicated a determined effort to kill, negating self-defense. Conspiracy was established through the concerted actions of Francis, Nicholas, and Diego in ensuring Jeffrey could not defend himself. The penalty of reclusion perpetua was affirmed. The Court modified the awarded damages, ordering Francis to pay the heirs of Jeffrey PHP 75,000.00 as civil indemnity, PHP 75,000.00 as moral damages, PHP 75,000.00 as exemplary damages, and interest at 6% per annum on all damages from finality of judgment until full payment.