People vs.
De los Reyes
G.R. No. 140680 (May 28, 2004)
Reny de los Reyes got life for
murdering Felomeno Omamos;
Supreme Court upheld conviction,
denied self-defense.
Facts:
On January 13, 1998, at
approximately 4:00 PM, Reny de
los Reyes (the appellant) fatally
stabbed Felomeno Omamos (the
victim) in Sitio Digcamara,
Barangay Mapulog, Naawan,
Misamis Oriental. The incident
occurred after the appellant
borrowed a stainless steel knife
from his uncle, Mario de los Reyes,
and subsequently followed the
victim, who was accompanied by
his five-year-old son and wife,
Annaliza.
As the victim was walking to tether
their cow, the appellant attacked
him from behind, stabbing him
multiple times, including in the
back, elbow, and chest. Annaliza
witnessed the attack and shouted
for help. The victim was taken to
the hospital but succumbed to his
injuries later that evening. The
cause of death was determined to
be hypovolemic shock due to
massive hemothorax from stab
wounds.
The prosecution presented
witnesses, including Annaliza and
Myrnaflor Gaid, who testified about
the events leading to the stabbing.
The defense, on the other hand,
claimed self-defense, asserting
that the victim had threatened the
appellant prior to the attack and
had thrown a stone at him,
prompting the appellant to act in
self-defense.
Legal Issues:
1. Whether the appellant acted in
self-defense or if the killing
constituted murder.
2. Whether the trial court
correctly appreciated the
qualifying circumstances of
treachery and evident
premeditation.
3. The appropriateness of the
damages awarded to the
victim's heirs.
Arguments:
Prosecution:
The prosecution argued that
the appellant acted with
treachery and evident
premeditation, as he had
borrowed a knife and followed
the victim before attacking him
from behind, ensuring the
victim had no opportunity to
defend himself.
Witnesses testified that the
appellant stabbed the victim
multiple times without
provocation, indicating a
deliberate intent to kill.
Defense:
The defense contended that
the appellant acted in self-
defense, claiming that the
victim had threatened him and
initiated the aggression by
throwing a stone.
The appellant argued that he
only retaliated after the victim
attacked him with a knife,
asserting that he had no choice
but to defend himself.
Court's Decision and Legal
Reasoning:
The court dismissed the appeal,
affirming the trial court's decision
to convict the appellant of murder.
The court found that the
appellant's claim of self-defense
was not credible, as he failed to
prove the essential elements
required for self-defense,
particularly unlawful aggression on
the part of the victim. The court
emphasized that once the appellant
wrested the knife from the victim,
the aggression had ceased, and
any subsequent stabbing
constituted retaliation rather than
self-defense.
The court also upheld the trial
court's findings regarding
treachery and evident
premeditation. It noted that the
appellant had taken steps to
prepare for the attack by borrowing
a knife and that the attack was
executed in a manner that deprived
the victim of any chance to defend
himself. The court found that the
prosecution had sufficiently
established the elements of
treachery and evident
premeditation.
Regarding damages, the court
modified the amounts awarded to
the victim's heirs, reducing the civil
indemnity to P50,000, moral
damages to P50,000, and funeral
expenses to P25,000, aligning with
prevailing jurisprudence.
Significant Legal Principles
Established:
1. Self-Defense: The burden of
proof lies with the accused to
establish the elements of self-
defense, including unlawful
aggression, reasonable
necessity of the means
employed, and lack of
sufficient provocation.
2. Treachery: For treachery to be
present, the attack must be
sudden and unexpected,
depriving the victim of any
opportunity to defend
themselves.
3. Evident Premeditation: This
requires proof of a prior
determination to commit the
crime, an act indicating the
accused's adherence to that
determination, and a sufficient
lapse of time for reflection.
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