THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. NAPOLEON MARANAN Y ANGCO, DEFENDANT-APPELLANT.

People versus Maranan

The Case

This is the People of the Philippines against Napoleon Maranan, a criminal appeal by automatic review from a judgment of conviction for murder, frustrated murder, and attempted murder, arising from a single bolo attack on five men in Amadeo, Cavite. The accused admitted hacking all five victims but claimed self-defense. The case matters for two reasons: it is a clean teaching vehicle on the burden of proof in self-defense, on flight as evidence of guilt, and on treachery; and it settles a jurisdictional race between two courts over the same incident, showing how the court that first takes cognizance of a case acquires exclusive jurisdiction.

Procedural History

Two sets of informations were filed against the accused covering the same incident. One set, five informations for murder, frustrated murder, and attempted murder, was filed in the Circuit Criminal Court of Pasig, Metro Manila. The other set, for murder, double murder, and slight physical injuries, was filed in the Court of First Instance of Cavite. The accused moved to dismiss the Pasig cases on the ground that the Cavite court had already acquired jurisdiction. The motion was not resolved in his favor; he pleaded not guilty in the Circuit Criminal Court, and that court began trial on the merits. He then filed a petition for certiorari with the Supreme Court, asking that the Pasig court be restrained from proceeding. While that petition was pending, the Circuit Criminal Court rendered its decision convicting him and imposing the death penalty. The case came to the Supreme Court on automatic review, and the certiorari petition was resolved together with the review.

Facts

At about eleven o'clock in the evening of February 1, 1977, Edgardo Bayani and Edilberto Bay were returning home from a wake. They stopped on the street in Barrio Maymangga, Amadeo, Cavite, to listen to Rodolfo, Efraim, and Nolasco Villanueva, who were talking with Isaias Bayani in front of the councilor's house. The accused suddenly arrived and hacked them one after another with a bolo about twenty centimeters long. He first hit Edgardo on the left shoulder, then Edilberto on the chest, then Rodolfo on the head, then Nolasco in the face, and finally Isaias on the neck, fatally. The victims identified him as a co-farmer and townmate, and testified that the attack was so sudden they could not move or parry the blows. The physicians testified that Nolasco lost the sight of his left eye, that Rodolfo's speech was impaired, and that Isaias died from the cutting of the carotid and jugular veins.

The accused gave a different account. He claimed that Edgardo and Edilberto invited him to drink, that he refused, and that they boxed and stoned him; that the two drew their knives, so he took the initiative and hacked them with his bolo; and that Rodolfo, Nolasco, and Isaias then attacked him with a piece of wood and a chain, until gunshots from Romeo Bay and the sight of Jeremias Villanueva with a gun made him flee toward his sister's house.

The trial court found the prosecution version credible. The accused admitted the hacking but failed to support self-defense with clear and convincing evidence. He suffered no injury at all despite supposedly facing five armed men. He admitted ill feelings between his family and the Villanuevas because Nolasco had been charged with a crime against chastity against his sister. And he went into hiding after the incident instead of surrendering and reporting that he had acted in self-defense.

Issues

• Whether or not the accused acted in self-defense, such that his admission of hacking all five victims should be excused.
• Whether or not the trial court properly convicted him of the crimes charged, including a finding of treachery.
• Whether or not the Circuit Criminal Court of Pasig had jurisdiction to try and decide the cases, given the pendency of the parallel informations in the Court of First Instance of Cavite.

Applicable Provisions

The decision does not quote a penal or procedural provision verbatim; it applies Republic Act Number 5179, as amended by Presidential Decree Number 126, on the jurisdiction of the Circuit Criminal Court. That law bears on the case because it defines the territorial reach of the Seventh Judicial District and the concurrence of jurisdiction with the Court of First Instance, which controls the third issue.

Ruling

On the first issue, the Court held that self-defense, being an admission of the killing, must be supported by clear and convincing evidence, and the defense miserably failed. The accused's testimony stood alone. It defied human credulity that he emerged without a single injury after five men allegedly attacked him simultaneously with deadly weapons, and he showed no extraordinary strength or dexterity to explain it. The Court also weighed his motive, the long-standing grudge over the charge against his sister, and his flight. Flight after the commission of the crime, the Court said, is highly evidentiary of guilt and incompatible with self-defense.

On the second issue, the Court affirmed the conviction. Intent to kill was manifest from the nature and location of the wounds. Treachery was established by the suddenness of the assault, which made it impossible for the unsuspecting victims to parry or avoid the blows.

On the third issue, the Court dismissed the certiorari petition. Under Republic Act Number 5179 as amended, the judge of the Circuit Criminal Court of the Seventh Judicial District, stationed at Pasig, had jurisdiction over offenses committed in Cavite, which lay within the same district. Although its jurisdiction was generally concurrent with that of the Court of First Instance, the cases were filed in the Circuit Criminal Court on June 21, 1977, and in the Cavite court two days later, so exclusive jurisdiction vested in the Circuit Criminal Court. The respondent judge did not act without or in excess of jurisdiction.

Doctrine

First, self-defense is an admission of the act and shifts the burden to the accused, who must prove it by clear and convincing evidence; a bare, uncorroborated testimony that is contrary to human experience cannot overcome the prosecution's evidence. Second, flight after the commission of the crime is highly evidentiary of guilt and incompatible with self-defense. Third, intent to kill is shown by the nature and location of the wounds, and treachery is established by a sudden attack that leaves the victims no opportunity to defend themselves. Fourth, when two courts have concurrent jurisdiction, the court that first acquires jurisdiction over the case retains it to the exclusion of the other.

Disposition

The certiorari petition was dismissed, the judgment of conviction was affirmed, and the death penalty was reduced to reclusion perpetua for lack of the necessary votes, with the civil indemnity to the heirs of Isaias Bayani increased from 12,000 pesos to 30,000 pesos.

Remember This

Memorize the line that flight is highly evidentiary of guilt and incompatible with self-defense. Examiners use this case for the burden of proof in self-defense and for the rule that the court first taking cognizance of a case acquires exclusive jurisdiction over a later-filed parallel case.