Case Digest: PEOPLE OF THE PHILIPPINES v. ROBERTO PAJABERA y DOE 582 SCRA 763 (2009)

PEOPLE OF THE PHILIPPINES v. ROBERTO PAJABERA y DOE 582 SCRA 763 (2009)

Findings of fact by the trial court, when affirmed by the appellate court, are afforded greatest respect. Roberto Pajabera was charged with Murder before the Regional Trial Court of Camarines Sur. Pajabera admitted having stabbed Bolanos. He alleged however that he did so because of self-defense. By his account, he and Bolanas had a wager, and he won. When he tried to collect his winning, Bolanos refused to pay and instead he pulled out a bladed instrument and attacked him with it. Pajabera further alleged that when they were grappling for the possession of the bladed instrument he accidentally pushed the bladed instrument unto Bolanos‘ shoulder. The trial court convicted Pajabera of murder, qualified by treachery. It rejected Pajabera‘a claim of self-defense and found it improbable that the victim could be accidentally hit on the shoulder with the knife during the respective positions of the parties as described by Pajabera. On appeal, the Court of Appeals affirmed the trial court‘s decision, holding that Pajabera failed to discharge the burden of proving self-defense.

ISSUE:

Whether or not Pajabera‘s claim of self-defense must be admitted

HELD:

It is settled that the issue of credibility is a question best addressed to the trial court, and that its findings of fact, especially when affirmed by the appellate court as in the present case, are accorded the greatest respect in the absence of a showing that it ignored, overlooked, or failed to properly appreciate matters of substance or importance likely to affect the results of the litigation. Independently of the factual findings of the lower courts, this Court, in its review of the records, found the findings in order. Pajabera would have it that he was lying with his back flat on the floor while the victim was kneeling and stooping down on him holding the knife. Given that, the thrust of the knife could only have been downwards pointing to Pajabera. Even assuming that Pajabera was able to twist the victim‘s hand which held the knife, it was unlikely that Pajabera could “accidentally” stab the victim on the right shoulder. Pajabera‘s attack having been made in a swift and unexpected manner on the unsuspecting and unarmed victim who did not give the slightest provocation, treachery attended the killing. Perforce, appellant‘s conviction for Murder stands.