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NICOLAS VELASQUEZ v. PEOPLE

FACTS:

Accused petitioners Nicolas Velasquez and Victor Velasquez, along with four others, were charged with attempted murder. The Regional Trial Court found them guilty beyond reasonable doubt of attempted murder based on the prosecution's claim that the accused attacked and assaulted Jesus Del Mundo, causing him injuries. The defense, however, presented a different version of events, asserting that the accused acted in response to Jesus' aggressive behavior. The Regional Trial Court sentenced the petitioners to imprisonment. The Court of Appeals affirmed the decision but modified the charge to serious physical injuries. Petitioners filed a petition for review, contending that they acted in self-defense. The crucial issue to be resolved is the sufficiency of the evidence to prove the existence of justifying circumstances and to convict the petitioners.

ISSUES:

  1. Whether there was sufficient evidence to prove the existence of justifying circumstances.

  2. Whether the petitioners can be held criminally liable for the physical harm inflicted on the victim.

  3. Whether the petitioners were able to establish the elements of self-defense and defense of a relative.

  4. Whether the testimony of Maria Teresita is credible and sufficient for the conviction of the petitioners.

  5. Whether the inconsistencies in Jesus' testimony regarding the specific details of the assault affect his credibility.

  6. Whether Jesus' testimony is sufficient to establish the guilt of the petitioners and their co-accused.

RULING:

  1. The Court held that there was no sufficient evidence to prove the existence of justifying circumstances. In invoking self-defense, the burden of evidence is shifted to the accused, who must establish the elements of unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation. The burden requires credible, clear, and convincing evidence. Self-defense cannot be appreciated when uncorroborated by independent and competent evidence or when it is extremely doubtful. In this case, the accused failed to provide such evidence.

  2. The Court ruled that the petitioners can be held criminally liable for the physical harm inflicted on the victim. Since they failed to establish self-defense or defense of a relative, the accused cannot escape criminal liability for the harm they inflicted on the victim.

  3. The Court found that the petitioners failed to establish the elements of self-defense and defense of a relative. They were unable to prove that the unlawful aggression originated from the victim, Jesus. The injuries sustained by Jesus were also disproportionate to any supposed aggression. Thus, the petitioners failed to satisfy the second requisite of self-defense and defense of a relative.

  4. The Court stated that the characterization of Maria Teresita as the "lone eyewitness" was erroneous. Jesus also testified about the incident. The fact that Maria Teresita separated from Ana while searching for Jesus does not diminish her credibility. The Court found no reason to doubt her testimony. Furthermore, the alleged inconsistencies in Jesus' recollection of events were considered too trivial to affect his overall credibility.

  5. The alleged inconsistencies in Jesus' testimony regarding the intricacies of the assault do not affect his credibility. The court recognizes that a victim's recollection of a traumatic experience cannot be expected to be mechanically accurate. The credibility of Jesus' testimony is based on his credible narration of his entire ordeal.

  6. Jesus' testimony is deemed sufficient to establish the guilt of the petitioners and their co-accused. The court affirms the Decision of the Court of Appeals, which found the petitioners and their co-accused to be the authors of the crime.

PRINCIPLES:

  • In self-defense, the accused admits to having inflicted harm but justifies it as necessary to protect oneself or a relative from an imminent threat. The burden of evidence is shifted to the accused to prove the elements of self-defense.

  • The elements of self-defense are: unlawful aggression, reasonable necessity of the means employed, and lack of sufficient provocation.

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

  • Defense of a relative requires the same elements as self-defense, with the additional requirement that the person making the defense had no part in the provocation.

  • To claim self-defense, the accused must prove that there was unlawful aggression, reasonable necessity of the means employed to prevent or repel it, and lack of sufficient provocation on the part of the person claiming self-defense. The beating dealt to the alleged aggressor must be proportionate to the aggression.

  • In assessing witness testimony, minor inconsistencies or lapses in recollection are to be expected, especially in events that transpired rapidly and in highly emotional situations. The overall credibility and coherence of the testimony should be considered.

  • A victim's recollection of a harrowing and traumatic experience cannot be expected to be mechanically accurate.

  • The merit of a witness's testimony does not solely depend on their ability to recall every minutiae, but rather on their credible narration of the entire ordeal.

  • It is within the court's discretion to determine the credibility of witnesses and the weight to be given to their testimony.

  • Testimony that is credible and establishes the guilt of the accused can be sufficient evidence to convict.