G.R. No. 227502 - PEOPLE OF THE PHILIPPINES, VS. RANDY GAJILA Y SALAZAR, ACCUSED-.D E C I S I O N - Supreme Court E-Library

Ruling

Accordingly, the RTC sentenced appellant to suffer the penalty of reclusion perpetua . It likewise ordered appellant to pay the heirs of the victim: P50,000.00 as civil indemnity, P47,641.50 as actual damages, and P1,916,250.00 for the loss of the victim's earning capacity. [19] Appellant thereafter appealed the RTC Decision before the CA. Ruling of the Court of Appeals In its Decision dated September 10, 2015, the CA affirmed the assailed RTC Decision with modifications, in that the appellate court: ( a ) directed appellant to pay the heirs of the victim P75,000.00 as moral damages and P30,000.00 as exemplary damages; ( b ) increased the award of civil indemnity to P75,000.00; ( c ) decreased the amount of loss of earning capacity to P1,383,286.95; and ( d ) imposed interest at the rate of 6% per annum on all damages awarded from the date of finality of the Decision until fully paid. [20] The CA agreed with the RTC's finding that appellant had failed to clearly and convincingly prove the elements of self-defense. [21] It also pointed out that appellant himself testified that Ross (the prosecution's eye witness) held no grudges against him and that he had no hostile encounter with the latter. [22] In addition, the CA held that the victim's killing was indeed qualified by treachery. [23] It noted that, while the victim was busy weighing pork meat on a scale, appellant approached him from behind, strangled his neck and, while in such position, stabbed him at the right side. [24] "A sudden attack against an unarmed victim, such as in this case, clearly constitutes treachery." [25] Aggrieved, appellant filed the present appeal. The Issues Appellant raises the following issues for the Court's resolution: First , whether appellant was able to sufficiently prove the justifying circumstance of self-defense; And second , whether the victim's stabbing was attended by treachery. The Court's Ruling The appeal is unmeritorious. In criminal cases, the burden lies upon the prosecution to prove the guilt of the accused beyond reasonable doubt. [26] However, when the accused invokes self­ defense, the burden of proof is shifted from the prosecution to the defense, [27] and it becomes incumbent upon the accused to prove, by clear and convincing evidence, the existence of the following requisites of self-defense: first , unlawful aggression on the part of the victim; second , reasonable necessity of the means employed to prevent or repel such aggression; and third , lack of sufficient provocation on the part of the person defending himself. [28] In such cases, the accused must rely on the strength of his evidence and not on the weakness of the prosecution's evidence. After all, by invoking self-defense, the accused, in effect, admits having killed or injured the victim , and he can no longer be acquitted of the crime charged if he fails to prove the essential requisites of self-defense. [29] The most important requisite of self-defense is unlawful aggression which