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PEOPLE v. CECILIO BINONDO

FACTS:

The accused-appellant, Cecilio Binondo, appealed his murder conviction while his co-accused, Rosendo Binondo, Valentina Binondo, Nicolasa Binondo, Damian Soriano, and Severino Dinopol, were acquitted. The accused-appellant maintains that the trial court erred by dismissing his plea of self-defense and failing to consider mitigating circumstances. On February 23, 1986, the accused-appellant was seen by his neighbors, Maximo Dinopol and Pablita, carrying a dead body into his yard. According to witnesses, he assured them not to worry as he would shoulder the responsibility. Later that evening, he went to the police station with the decapitated head of the victim. The police conducted an investigation, retrieved the body from the accused-appellant's house, and performed an autopsy. The accused-appellant claims that he killed the victim in self-defense after the victim approached him in an angry mood, armed with a gun and a bolo, and threatened to harm him and his family.

ISSUES:

  1. Did the trial court err in disregarding the accused-appellant's plea of self-defense and finding him guilty beyond reasonable doubt of the crime of murder?

  2. Did the trial court err in not appreciating the mitigating circumstances in favor of the accused-appellant?

RULING:

  1. The Supreme Court affirmed the trial court's decision. It held that self-defense should fail as a defense in this case as there was no unlawful aggression on the part of the victim. The accused-appellant's version of the events was inconsistent and not supported by the evidence. Thus, the trial court was correct in finding him guilty beyond reasonable doubt of the crime of murder.

  2. The Supreme Court ruled that the trial court did not err in not appreciating the mitigating circumstances in favor of the accused-appellant. The accused-appellant failed to prove the presence of any mitigating circumstance that would reduce his liability.

PRINCIPLES:

  • Self-defense as a justifying circumstance requires unlawful aggression on the part of the victim. (Issue 1)

  • Inconsistency in the accused's version of events and lack of evidence to support it may result in the rejection of self-defense as a defense. (Issue 1)

  • The burden of proving the presence of mitigating circumstances lies with the accused. (Issue 2)