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Crim Law 1 Case Digest: People v. Daleba

People v. Daleba
G.R. No.  168100   November 20, 2007

Lessons Applicable: Treachery, Evident Premeditation, Self-Defense, Murder

Laws Applicable:


    March 18, 1997: Renato Angeles and Mateo Daleba, Jr., “barkers” in a bus terminal in Pasay City, quarreled over the division of their earnings.  Edwin Bernarte intervened and pacified them. Renato walked away and headed to his house near the terminal. While, Daleba joined Bernarte’s group who had just taken their lunch nearby.   Suddenly, Daleba ran after Renato, pulled a knife from his waistline, held Renato’s shoulder by his left hand, slashed Renato on the right forearm and stabbed him at the back, above the right side of the waistline. Renato died that evening from the stab wound. Appellant, who had gone to his home province in Camarines Sur, was arrested four years after the stabbing incident
    Prosecution presented 2 witness who witnessed the quarrel and stabbing
    Daleba invoked self-defense

o    he went to the Pasay City bus terminal and once inside,  Renato suddenly grabbed his neck, dragged him to the back of the terminal, and, using his right hand which also held a knife, repeatedly boxed him in the face. Once he was able to free himself from Renato’s hold, he grabbed a knife lying at a nearby table and stabbed Renato with it. Renato had earlier assaulted him at around 9:00 a.m. of the same day.

    RTC: Murder qualified by treachery and evident premeditation
    Daleba appealed that RTC erred in appreciating the qualifying circumstance of treachery since the quarrel which preceded the killing must have put Renato on-guard
    CA: affirmed RTC because of the interval of time between the quarrel and stabbing

ISSUE: W/N there was treachery

HELD: YES. CA affirmed with modification.

    By invoking self-defense, he effectively admitted committing the acts leading to Renato’s death  under circumstances justifying its commission.  If, indeed,  Renato suddenly attacked him inside a bus terminal in broad daylight by grabbing him by the neck and dragging him towards the back of the terminal, the ensuing commotion would have attracted the attention of the people around them. Yet, he couldn’t explain why there was no rescue.
    There is treachery when the offender commits any of the crimes against the person, employing means, methods, or forms in the execution thereof which tend directly and specially to insure its execution, without risk to himself arising from the defense that the offended party might make
    This circumstance will be appreciated if

o    (1) at the time of the attack, the victim was not in a position to defend himself

§  Renato was walking away

o    (2) the offender consciously adopted the form of attack he employed

§  Stabbed from behind