G.R. No. 223155 - PEOPLE OF THE PHILIPPINES, VS. DANILO JAPAG AND ALVIN LIPORADA, ACCUSED, DANILO JAPAG, 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: P75,000.00 as civil indemnity, P75,000.00 as moral damages, P30,000.00 as exemplary damages, and P17,500.00 as actual damages. [13] The RTC also issued an alias warrant of arrest against Liporada "to be served in his residence or anywhere where he could be found within the territory of the Philippines." [14] Appellant thereafter appealed the RTC Decision before the CA. Ruling of the Court of Appeals In its Decision dated May 21, 2015, the CA affirmed the assailed RTC Decision with modification as regards the imposition of interest at 6% per annum on all damages awarded from date of finality of the judgment until fully paid. [15] Like the RTC, the CA also rejected appellant's claim of self-defense in the absence of proof of unlawful aggression on the part of the victim. [16] It noted that Ramil's "clear and detailed account of the incident negate[d] any hint that the unlawful aggression originated from the victim," [17] as did the nature and location of the wound sustained by the latter. [18] The CA further ruled that the elements of the qualifying circumstance of treachery were present in the case, since "[t]he victim had no chance to avoid the attack when he was boxed by Alvin first and then suddenly stabbed from behind by [appellant], while being held by Eman." [19] It thus concluded that under those dire circumstances, the victim could not have had the chance to defend himself. [20] 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; [21] And second , whether the victim's stabbing was attended by treachery. [22] The Court's Ruling The appeal is unmeritorious. It is settled that when an accused invokes self-defense, the burden of proof is shifted from the prosecution to the defense, [23] 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. [24] As the burden of proof is shifted to the defense, 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 exonerated of the crime charged if he fails to prove the requisites of self-defense. [25] The most important requisite of self-defense is unlawful aggression which is the condition sine qua non for upholding self-defense as a justifying circumstance. [26] In other words, unless it is sho