FACTS:

The case involves an appeal filed against the decision of the Court of Appeals (CA) that affirmed the decision of the Regional Trial Court (RTC) finding the accused-appellant guilty of Murder. The case originated from an information charging the accused-appellant with Murder. The prosecution presented witnesses who testified on the events leading to the crime. According to their testimonies, on August 4, 1997, the victim was having a meal when the accused-appellant entered the house and stabbed him from behind. The accused-appellant tried to pull the victim outside but failing to do so, stabbed him again. The victim's daughter begged the accused-appellant to stop, but he ignored her pleas. The victim was brought to the hospital but died after ten days. The defense presented the accused-appellant as its lone witness, who claimed self-defense. According to the accused-appellant, he had an altercation with the victim during a drinking session because the victim spread gossips about the accused-appellant's sister. The accused-appellant claimed that the victim hurt him during the altercation, which led to the stabbing. The RTC found the accused-appellant guilty of murder and sentenced him to reclusion perpetua. The CA affirmed the decision of the RTC.

The accused-appellant filed an appeal before the Supreme Court, arguing that the RTC erred in convicting him of murder and failed to prove the elements of self-defense. The Office of the Solicitor General (OSG) countered that the accused-appellant's guilt has been proven beyond reasonable doubt and supported the RTC's findings of treachery in the commission of the crime.

ISSUES:

1. Whether the trial court's findings on the credibility of witnesses should be given respect and finality.

2. Whether accused-appellant successfully proved self-defense.

3. Whether treachery attended in the commission of the crime.

4. Whether there was treachery in the commission of the crime.

5. Whether the stab wound was the proximate cause of the victim's death.

6. Whether there is a rational connection between the act of accused-appellant stabbing the victim and the resulting death.

7. Whether there is evidence of an efficient intervening active force that could have caused the victim's death.

8. Whether the act of the accused-appellant accelerated or contributed to the victim's death.

9. Whether the penalty imposed is correct.

10. Whether the awards for civil indemnity, moral damages, exemplary damages, actual damages, and temperate damages are proper.

11. Whether the imposition of 6% interest per annum on all monetary awards is proper.

RULING:

1. Yes, the trial court's findings on the credibility of witnesses should be given respect and finality, unless there are glaring errors, gross misapprehension of facts, and speculative, arbitrary, and unsupported conclusions.

2. No, accused-appellant failed to prove self-defense. Self-defense is an affirmative allegation that shifts the burden of evidence to the accused. The essential elements of self-defense must be established, including unlawful aggression on the part of the victim, reasonable necessity of the means employed to prevent or repel the aggression, and lack of sufficient provocation on the part of the person defending themselves. In this case, there was no evidence of unlawful aggression on the part of the victim as it was accused-appellant who was the aggressor.

3. Yes, treachery attended in the commission of the crime. Treachery exists when the offender deliberately chooses a method of attack to ensure the execution of the crime without risk to themselves. In this case, accused-appellant suddenly entered the house and stabbed the victim while the latter was eating his meal, making it evident that the attack was done without warning and in a manner that ensured the victim's vulnerability and defenselessness.

4. Yes, there was treachery in the commission of the crime. The Court held that treachery exists when the offender employs means, methods, or forms in the execution of the criminal act which tend to directly and especially ensure its execution without risk to the offender arising from the defense that the victim might make. In this case, the accused suddenly entered the victim's kitchen and immediately stabbed the victim while he was having his meal. The unexpectedness of the attack deprived the victim of any chance to defend himself, thus ensuring the consummation of the offense without risk to the accused. The Court also noted that the accused was already armed with a bladed weapon when he entered the victim's house, which indicates that the mode of attack was preconceived by the accused.

5. Yes, the stab wound was the proximate cause of the victim's death. The Court held that the accused is criminally liable for all the natural and logical consequences resulting from the felony committed, unless there was an efficient intervening active force that intervened between the felony and the resulting injury. In this case, although the immediate cause of the victim's death was cardiorespiratory arrest, the stab wound inflicted by the accused on the vital part of the victim's body was the proximate cause of the victim's death. The Court emphasized that the cause and effect relationship is not altered or changed by pre-existing conditions or concurrent conditions, as long as the felony committed caused or contributed to the resulting injury or death.

6. Yes, there is a rational connection between the act of accused-appellant stabbing the victim and the resulting death. The stab wound caused the victim to be hospitalized and eventually led to his death.

7. No, there is no evidence of an efficient intervening active force that could have caused the victim's death. The Medical Certificate does not indicate the occurrence of any efficient intervening cause that broke the relation between accused-appellant's act and the resulting death.

8. Yes, even if the victim was previously suffering from a disease or ailment, accused-appellant is still liable because his act of stabbing the victim hastened or accelerated the victim's death.

9. The penalty of reclusion perpetua imposed is correct in accordance with Article 248 of the Revised Penal Code.

10. The awards for civil indemnity, moral damages, exemplary damages, and actual damages are proper and are in accordance with the case of People v. Jugueta. However, the award for temperate damages should be increased from P20,000.00 to P50,000.00 to conform with Jugueta. The imposition of 6% interest per annum from the finality of the decision until full payment is also proper.

11. The imposition of 6% interest per annum on all monetary awards from the finality of the decision until full payment is proper.

PRINCIPLES:

• Treachery exists when the offender employs means, methods, or forms in the execution of the criminal act which tend to directly and especially ensure its execution without risk to the offender arising from the defense that the victim might make.

• Proximate cause is that cause which in the natural and continuous sequence, unbroken by an efficient intervening cause, produces the injury or death, and without which the result would not have occurred. The felonious act of the offender must be the proximate cause of the resulting injury or death.

• The cause and effect relationship between the felony committed and the resulting injury or death is not altered or changed by pre-existing conditions or concurrent conditions, as long as the felony committed caused or contributed to the resulting injury or death.

• There must be a rational connection between the act of the accused and the resulting death for him to be held criminally liable.

• An efficient intervening active force, not connected with or absolutely foreign to the act of the accused, must be proven to break the relation of the felony and the resulting death.

• Even if the victim was previously suffering from a disease or ailment, the accused is still liable if his act hastened or accelerated the victim's death.

• The penalty for murder prescribed by Article 248 of the Revised Penal Code is reclusion perpetua.

• The awards for civil indemnity, moral damages, exemplary damages, and actual damages are proper in cases of murder.

• The award for temperate damages should be increased from P20,000.00 to P50,000.00 to conform with prevailing jurisprudence.

• Interest at the rate of 6% per annum shall be imposed on all monetary awards from the finality of the decision until full payment.