P/C Supt. Edwin A. Pfleider v. People of the Philippines G.R. No. 208001, 19 June 2017 Facts: Facts: At around 7 :00 a.m. of September 15, 2010, Granados was fatally shot by Bautista in front of his home in Tacloban City. After the shooting, Bautista attempted to flee the crime scene but was unsuccessful because his getaway motorcycle failed to start its engine. A neighbor of the victim, Butch Price, came to the rescue and shot and wounded Bautista. Granados was immediately rushed to the hospital but was declared dead. Bautista was also brought to the hospital. On the same day, SP02 Norman Loy Fevidal interviewed Bautista while the latter was still confined. Bautista executed an extrajudicial confession implicating Pfleider as the mastermind of the assassination claiming that Pfleider induced him by means of a price of P60,000 for the hit. An Information for Murder was filed with the RTC of Tacloban but the judge dismissed the case for lack of probable cause. However, the OSG filed filed a certiorari with the CA which was granted. Hence, this petition questioning the reversal of the CA of the finding of lack of probable cause by the RTC. Issue: Whether Issue: Whether or not the determination of the presence of probable cause may be made by the Supreme Court. Ruling: NO. NO. It must be emphasized that the SC is not a trier of facts. The determination of probable cause is and will always entail a review of the facts of the case. The CA, in finding probable cause, did not exactly delve into the facts of the case but raised questions that would entail a more exhaustive review of the said facts. It ruled that, "Questions remain as to why, among all people, Ryan would implicate Pfelider as the inducer and why the other witnesses would associate Pfleider to the crime." From this query, the CA has raised doubt. In this case, the judge of the RTC, not finding the existence of probable cause, outrightly dismissed the case. The contrasting findings findings of the CA and the RTC is well noted and from the very provision of the Rules of Court, the remedy, in case of doubt, is for the judge to order the prosecutor to present additional evidence. Therefore, the SC finds it appropriate to remand the case to the trial court for its proper disposition, or for a proper determination of probable cause based on the evidence presented by the prosecution. Note: Because of the demise of P/C Supt. Edwin A. Pfleider, instead of remanding the case to the Regional Trial Court of Tacloban city for the determination of probable cause, the criminal action is DISMISSED, DISMISSED, there being no defendant to stand as accused.
People of the Philippines v. Demetrio Sabida y Sadiwa G. R. No. 208359, 19 June 2017 Facts: On July 7, 2009, at 6:30 a.m., Richard Pimentel and the victim, MacArthur Mawac, were walking to attend to their own errands when Sabida unexpectedly emerged from the road and repeatedly stabbed and hacked Mawac with a bolo. Afterwards, Sabida turned to Pimentel and uttered, "Isa ka pa, " prompting the latter to run away. Sabida run after him but he failed to catch him. Pimentel immediately reported the incident to Brgy. Captain Hintay, who in turn reported the incident to the police station of Pinamalayan. Sabida admitted killing Mawac and invoked self-defense. He said that he had a misunderstanding with Mawac and the latter's wife because the couple accused his domestic animals of destroying their palay. He alleged that the couple retaliated by poisoning and stealing his chickens and other farm. He said that on the day of the incident, he saw Pimentel and Mawac walking by and heard Pimentel warning Mawac to be careful as he was nearby to which Mawac allegedly responded, "Sige, unahan mo na. " This prompted him to confront the two and ask why Mawac was intending to kill him when what he merely wanted to know is where his chicken went. He said that Mawac tried to draw out the bolo tucked under his waist but Sabida was able to defend himself so they struggled and fought off each other. He said that he left Mawac lying on the ground, who, even then, was still taunting him to continue fighting. The RTC rendered judgment convicting him of murder qualified by treachery. A MR was filed but was denied. His appeal with the CA was likewise denied. Hence, this petition. Issue: Whether the guilt of Sabida for the crime of murder has been proven beyond reasonable doubt. Ruling: YES. In attempting to escape liability, Sabida invokes self-defense. Upon invoking the justifying circumstance of self-defense, Sabida assumed the burden of proving the justification of his act with clear and convincing evidence. Having admitted the killing, Sabida is required to rely on the strength of his own evidence, not on the weakness of the prosecution's evidence, which even if it were weak, could not be disbelieved in view of his admission. However, based on the records and the evidence adduced by both parties, it is indisputable that Sabida failed to show that Mawac exhibited unlawful aggression against him. Being the party initiating the attack and armed with a deadly weapon, Sabida cannot successfully claim that there was unlawful aggression. Sabida's selfserving claim of self-defense coupled with the fact that he did not sustain any injury from his supposed attacker fails to support any claim of unlawful aggression.
