### Facts:
On September 15, 1996, in Barangay Tambulan, Tayasan, Negros Oriental, Philippines, Alfredo Senador was fatally stabbed by Elbert Callet y Sabanal, leading to Senador’s death. Callet was charged with Murder under Article 248 of the Revised Penal Code in the Regional Trial Court (RTC) of Negros Oriental, Dumaguete City, Branch 30. During his arraignment on June 11, 1997, Callet pled not guilty. The prosecution and defense presented their witnesses, establishing contradictory narratives of the incident.
The prosecution depicted a scene where Senador, his son Lecpoy, and Eduardo Perater were at a local flea market when Callet suddenly attacked Senador, stabbing him from behind. Witnesses, including Senador’s son, testified seeing Callet commit the act, subsequently fleeing the scene. An autopsy confirmed Senador’s cause of death as severe hemorrhage due to a stab wound.
Conversely, Callet presented a self-defense narrative, claiming a confrontation with Senador led to him stabbing Senador in a panic as Senador allegedly tried to attack him first. After the incident, Callet purportedly attempted to surrender to local authorities, fearing retaliation from Senador’s relatives.
The RTC found Callet guilty of murder, taking into account the mitigating circumstance of voluntary surrender but found no aggravating circumstances. Callet was sentenced to reclusion perpetua and ordered to pay indemnity to the victim’s heirs. Callet appealed the decision, challenging the RTC’s findings on treachery, self-defense, and the intention to commit so grave a wrong.
### Issues:
1. Whether the RTC erred in finding that the killing was characterized by treachery.
2. Whether the RTC erred in rejecting Callet’s plea of self-defense.
3. Whether Callet’s act lacked the intent to commit so grave a wrong as to mitigate his liability.
### Court’s Decision:
The Supreme Court affirmed the RTC’s decision, upholding Callet’s conviction for murder. On the issue of treachery, the Court found that the attack was sudden and unexpected, allowing no opportunity for Senador to defend himself, satisfying the element of treachery. Regarding self-defense, the Court pointed to the lack of credible evidence supporting Callet’s version of events, noting the improbability of his narrative and the absence of corroboration. On the issue of intent, the Court deemed that the manner of the attack indicated a clear intent to kill, thus not meriting consideration as a mitigating factor. The Court also upheld the RTC’s appreciation of voluntary surrender as a mitigating circumstance.
### Doctrine:
The Supreme Court reiterated the doctrine that for a plea of self-defense to be credible, it must be substantiated with clear and convincing evidence establishing unlawful aggression, reasonable necessity of means to prevent or repel such aggression, and lack of sufficient provocation on the part of the person defending themselves. Additionally, the Court demonstrated its consistent approach in evaluating claims of mitigating circumstances and reaffirmed the legal definition and threshold of treachery in establishing murder.
### Class Notes:
– **Self-Defense:** Requires evidence of (1) unlawful aggression, (2) reasonable necessity of means to prevent or repel, (3) lack of provocation by the person defending themselves.
– **Treachery (Alevosia):** Occurs when the offender employs means that ensure the execution of the crime without risk to themselves, arising from the defense the offended might make.
– **Mitigating Circumstances:** Acts that do not excuse a criminal act but are considered for reducing the degree of culpability (e.g., voluntary surrender).
– **Intent:** Assessed based on the manner of the act (e.g., use of weapon, aim, and execution).
– **Murder vs. Homicide:** Murder is distinguished by qualifying circumstances such as treachery.
### Historical Background:
This case reflects the Philippine legal system’s treatment of violent crimes and demonstrates the procedural journey from regional trial courts to the Supreme Court. It highlights the principles of substantive and procedural law in criminal proceedings, including the assessment of evidence, evaluation of witness credibility, and the application of legal doctrines in determining guilt and appropriate sentencing.
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