In the case of People of the Philippines v. Bonifacio Aliben, Diosdado Nicolas, and Ronnie Nicolas, the Supreme Court affirmed the conviction of the accused for murder, emphasizing that a claim of self-defense cannot stand when the aggression has ceased and the accused continues the attack. Additionally, the Court highlighted that when individuals act in concert with a common design to commit a felony, their actions constitute a conspiracy, making each participant equally responsible, thus clarifying the circumstances under which self-defense is invalidated by excessive force and reaffirming the principles of conspiracy in murder.

Stones, Secrets, and Swords: Did Self-Defense or Sinister Conspiracy Determine Juanito Bongon’s Fate?

The grim events unfolded on October 5, 1997, in Barangay Siba-o, Calabanga, Camarines Sur, where Juanito Bongon, Sr. met a violent end. The prosecution presented Romeo Barsaga, a mat vendor and eyewitness, who testified he saw Bonifacio Aliben hacking Bongon, while Diosdado Nicolas and Ronnie Nicolas struck him with pieces of wood. Floserfida Fabricante, the victim’s sister, corroborated this, seeing Aliben strike the victim with a bolo. Juanito Bongon, Jr., the victim’s son, recounted his father’s dying declaration, naming Dado and Ronnie as his attackers. The defense countered with Ronnie Nicolas claiming self-defense, alleging Bongon attacked him first with a balisong (folding knife) after a stone-throwing incident disrupted a card game. Diosdado Nicolas and Bonifacio Aliben denied involvement, asserting they were merely present at the scene. The trial court found Aliben, D. Nicolas and R. Nicolas guilty of murder, sentencing them to reclusion perpetua, a prison term of at least twenty years and one day to a maximum of forty years.

The central legal question was whether the accused acted in legitimate self-defense, and if not, whether their actions constituted conspiracy. The Supreme Court scrutinized the credibility of the prosecution’s eyewitnesses. Appellants argued that the witnesses’ testimonies were biased and inconsistent and that the victim’s dying declaration was inadmissible. However, the Court found no compelling reason to discredit the witnesses. It emphasized that different individuals react differently to shocking events, and minor inconsistencies in testimonies do not necessarily detract from their credibility. Moreover, it held that the requirements for a dying declaration were satisfied, making the victim’s statement admissible evidence.

Building on this foundation, the Supreme Court addressed Ronnie Nicolas’s claim of self-defense, which hinged on the presence of unlawful aggression from the victim. The Court ruled that even if Bongon initiated the aggression, it ceased when Ronnie gained control. Despite this, Ronnie continued to attack Bongon. “[T]he nature, number and location of the wounds sustained by the victim belie the assertion of self-defense since the gravity of said wounds is indicative of a determined effort to kill and not just to defend.” This excessive force invalidated the self-defense claim. The court cited the necropsy report and the testimony of Dr. Millena, and concluded that the severity of injuries and the weapons used suggested an intent to kill rather than merely defend.

Addressing the issue of conspiracy, the Supreme Court affirmed the trial court’s finding that the accused acted in concert. Citing existing jurisprudence, the Court noted:

Conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it. In the absence of direct proof of conspiracy, it may be deduced from the mode, method and manner by which the offense was perpetrated, or inferred from the acts of the accused themselves when such acts point to a joint purpose and design, concerted action and community of interest.

Witnesses testified that Aliben, D. Nicolas and R. Nicolas helped one another in attacking the victim, demonstrating unity of purpose and commonality of intent. Where conspiracy is established, the act of one conspirator is the act of all, making each participant liable as a co-principal. Even though Ronnie Nicolas admitted to killing Bongon, the denial of participation from Diosdado Nicolas and Bonifacio Aliben was insufficient to exonerate them given the credible eyewitness accounts and their proximity to the crime scene. Finally, the court agreed with the trial court that the killing was qualified as murder because of the aggravating circumstance of taking advantage of superior strength. The court stated that “[T]he 3 accused were all armed…and they helped one another in assaulting the victim who was alone.” The accused had a notable disparity in age and physique relative to that of the victim which shows superior strength.

FAQs

What was the key issue in this case?	The primary issues were whether the accused acted in self-defense and whether their actions constituted a conspiracy. The Court ruled against the claims of self-defense and confirmed conspiracy, resulting in murder convictions.
What constitutes unlawful aggression in self-defense?	Unlawful aggression is an actual, sudden, and unexpected attack or imminent threat thereof, endangering the life or limb of the person defending themselves. Without unlawful aggression, there can be no self-defense.
How does excessive force negate a claim of self-defense?	When the force used in self-defense exceeds what is reasonably necessary to repel the attack, the defense is no longer justified. The defense must only inflict harm reasonably equivalent to what is needed to prevent the unlawful aggression.
What elements are necessary for a valid dying declaration?	A dying declaration must concern the cause and circumstances of the declarant’s death, made under the consciousness of impending death, and the declarant must have been competent to testify if alive, offered in a case for homicide, murder, or parricide.
What is the legal definition of conspiracy?	Conspiracy exists when two or more persons agree to commit a felony and decide to carry it out. Proof of the agreement does not need to be direct, but can be shown through concerted actions displaying a common design.
What is the legal effect if conspiracy is established?	When conspiracy is proven, the act of one conspirator is the act of all, and all participants are held equally liable as co-principals in the crime.
How does superior strength factor into a murder charge?	Taking advantage of superior strength is an aggravating circumstance when there is a marked inequality of forces between the victim and aggressor, especially when exploited by the aggressor in committing the crime.
What penalties apply in the Philippines for a murder conviction?	Murder is punishable by reclusion perpetua to death, depending on the presence of aggravating or mitigating circumstances. Reclusion Perpetua carries a prison term of at least twenty years and one day to a maximum of forty years.

The Supreme Court’s ruling in People v. Aliben reinforces the legal standards for self-defense and conspiracy, emphasizing the need for proportional response in self-defense scenarios and illustrating how a shared criminal objective binds individuals together. These principles continue to shape Philippine criminal law and influence how similar cases are adjudicated.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Aliben, G.R. No. 140404, February 27, 2003