View full case

PEOPLE v. MELANIO NUGAS Y MAPAIT

FACTS:

Melanio Nugas y Mapait is appealing his conviction for murder. The Office of Provincial Prosecutor charged Jonie Araneta y Nugas with murder for allegedly conspiring with Nugas to attack and stab Glen Remigio y Santos, causing his death. Glen, his wife Nila, and their two children were traveling in their family vehicle when two men asked for a ride and subsequently threatened them with knives. One of the men stabbed Glen in the neck, resulting in his death. Nila identified Nugas as the person who stabbed her husband, and Araneta as the person who carried a maroon plastic bag found in the vehicle. Nugas claimed that he stabbed Glen in self-defense, as he believed Glen was reaching for a gun.

ISSUES:

  1. Whether the affirmance of the CA was proper.

  2. Whether the attendant circumstance of treachery was duly proven.

  3. Whether or not the accused had a valid claim of self-defense.

  4. Whether or not the element of treachery is present in the killing.

RULING:

  1. The appeal has no merit. The Court upheld the decision of the lower courts.

  2. The lower courts correctly found that the defendant failed to establish the requisites of self-defense. They also ruled that treachery had been duly proven.

  3. The court ruled that the accused did not have a valid claim of self-defense because there was no actual or imminent threat to his life. The accused failed to establish that the victim had punched him and reached for a clutch bag that made him believe that there was a gun inside. The court also found it highly improbable for the victim to launch an attack considering his position in the vehicle and the presence of his family.

  4. The court ruled that the element of treachery is present in the killing. The attack came without warning, and the victim was defenseless and unable to defend himself or retaliate. The accused stabbed the victim from behind with suddenness, ensuring the execution of the killing without any risk to himself from any defense the victim might make.

PRINCIPLES:

  • By pleading self-defense, an accused assumes the burden of proof to establish his plea by credible, clear, and convincing evidence.

  • Self-defense cannot be justifiably appreciated when it is uncorroborated by independent and competent evidence or when it is extremely doubtful by itself.

  • The accused must show that the victim committed unlawful aggression, there was reasonable necessity in the means employed to prevent or repel the aggression, and there was lack of sufficient provocation on the part of the accused.

  • Unlawful aggression is the primordial element of self-defense, and without it, there can be no justified killing in defense of oneself.

  • Unlawful aggression can be either actual or material, or imminent. It must involve a physical or material attack or assault that is offensive and positively strong.

  • Unlawful aggression is the main and most essential element to support the theory of self-defense.

  • Treachery is present when the means, methods, and forms of execution employed by the accused gave the person attacked no opportunity to defend himself or retaliate. The attack is swift, deliberate, and unexpected, ensuring the accomplishment of the attack without risk to the aggressor.