Case: People vs.

Manulit
G.R. No.: 192581:17
Date: November 2010

FACTS:

Accused Dennis Manulit shot Reynaldo Juguilon while the latter was walking with his live-
in partner Anabel. The shot resulted in Reynaldo’s death.

He then tucked the gun in his waist, raised his hands and shouted “wala akong ginawang
kasalanan at wala kayong nakita.” And he ran towards the basketball court adjoining the
barangay hall. Lydia Juguilon, Manulit’s aunt and the victim’s sister in law, saw what happened
but kept quiet about it until bothered by her conscience, she decided to issue a statement before
the prosecutor of Manila. Manulit offered a story of self-defense.

ISSUE:

Whether or not the accused act in self-defense?

RULING:

No the accused did not act in self-defense because he failed to prove the existence of
unlawful aggression which is one of the requisite to prove the claim of self-defense under article
11 of RPC.

RTC found him guilty of murder. The CA affirmed. The SC ruled that in the instant case,
Manulit failed to prove the existence of unlawful aggression. In addition, there was treachery
because the victim was only walking in the street when the accused-appellant suddenly shot him
at the back several times. He had no opportunity to defend himself, because he had no idea that
an attack was forthcoming. It likewise appears that the means was deliberately planned. What is
decisive is that the attack was executed in a manner that the victim was rendered defenseless
and unable to retaliate. Evidently, treachery attended the killing. Noteworthy also is the fact that
the accused-appellant held grudge against the victim since the victim filed a case against the
accused-appellant before the office of the city prosecutor.