G.R. No. L-66046 October 17, 1985
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARTURO PAMPANGA, accused-appellant.

FACTS

The prosecution evidence established that on the evening of February 2, 1980, in Tondo, Manila, accused-appellant Arturo Pampanga, accompanied by four others, approached Carlomagno Fajardo in front of a store. Pampanga confronted Fajardo about being mauled at a dance the previous night. After Fajardo replied, “ikaw kasi,” Pampanga suddenly stabbed him in the chest with a balisong knife. Eyewitnesses, including the storekeeper, saw the attack. The medico-legal report confirmed the fatal nature of the wound, which perforated the victim’s lung and heart, causing his death.
The accused-appellant claimed self-defense. He testified that during the encounter, Fajardo became angry, stood up as if to box him, and he retreated. He alleged he then picked up an object from the ground, stabbed Fajardo with it, and fled. He sought to justify his act based on the prior mauling incident, implying passion and obfuscation.

ISSUE

The core issue is whether the trial court correctly convicted Arturo Pampanga of murder qualified by treachery, and whether any mitigating circumstances attended the crime.

RULING

The Supreme Court affirmed the conviction for murder. The legal logic centered on the credibility of evidence and the proper appreciation of qualifying and mitigating circumstances. The Court found Pampanga’s claim of self-defense untenable as it was overwhelmingly contradicted by the clear, consistent, and credible testimonies of prosecution eyewitnesses who established he was the unlawful aggressor. The killing was qualified by treachery (alevosia). The Court ruled that treachery can exist in a sudden, face-to-face attack if it is deliberate and executed in a manner that ensures the execution of the crime without risk to the assailant from any defense the victim might make. Here, Pampanga’s sudden stabbing of the unarmed Fajardo, without any warning or opportunity to defend himself, squarely constituted treachery.
The Court rejected the alleged mitigating circumstance of passion and obfuscation. For this to be considered, the obfuscation must arise from lawful sentiments and must not be distant in time from the criminal act. The Court held that the mauling incident from the previous night was too remote, providing Pampanga sufficient time to recover his equanimity, and was rooted in a spirit of lawlessness and revenge, not a lawful cause. Furthermore, a plea of guilty was not mitigating as Pampanga had pleaded not guilty at arraignment. With no modifying circumstances, the penalty of reclusion perpetua was proper. The Court affirmed the judgment but increased the civil indemnity to the heirs of the deceased to P30,000.