Sabay vs.

People of the Philippines

G.R. No. 192150
October 01, 2014
Petitioner: Federico Sabay
Respondent: People of the Philippines
Ponenter: Brion, J.
FACTS:
On June 12, 2001,in Caloocan City, Metro Manila, the petitioner, Federico Sabay, and his daughter,
Erlinda, had an argument with Godofredo which later turned into a verbal altercation. Such argument was
rooted from the alleged intrusion of Federico and his daughter to the property of Godofredo. In the course of the
heated dispute among the parties, Erlinda hit Godofredo on the head with a hard object and the petitioner also
joined in by throwing a stone at Godofredos face.
Immediately thereafter, Jervie Lopez came and pacified the parties. However, he was hit in the hand
with a bolo.
On June 13, 2001, Godofredo and Jervie filed a complaint against Federico Sabay before the barangay.
The Medico Legal Certificates showed that Godofredo suffered contusion on the left parietal area of his head
and an abrasion in his left cheek, while Jervie sustained a wound in his right palm. Later on, the parties arrived
at an agreement called Kasunduang Pag-aayos as recommended by the building inspector. However, such
Kasunduan was not implemented due to the failure of the building inspector to make the promised
recommendation. Thus, the Office of the Barangay Captain issued a Certificate to File an Action before the
Metropolitan Trial Court, wherein, the petitioner was found guilty beyond reasonable doubt of 2 counts of slight
physical injuries. Furthermore, the court rejected the petitioners claim of self-defense for lack of clear,
convincing and satisfactory supporting evidence that there had been unlawful aggression by Godofredo. In due
course, the petitioner appealed the judgment to the Regional Trial Court, which fully affirmed the Metropolitan
Trial Courts decision. The petitioner sought recourse with the Court of Appeals which had also affirmed the
decision of the Regional Trial Court. It held that even if there had been no formal offer of exhibit pursuant to
Section 34, Rule 132 of the Rules on Evidence, the Certification to File an Action could still be admitted against
the adverse party. On March 22, 2010, the CA denied the petitioners motion for reconsideration. Hence, it lead
to the present petition for review on certiorari before the Supreme Court.
ISSUES:
a.) Whether or not the Metropolitan Trial Court has jurisdiction over the case in view of the alleged
inadmissibility of the Certification to File Action; and
b.) Whether or not the lower courts finding of guilt, its appreciation of the evidence and its rejection of the
claim of self-defense is valid.
HELD:
a.) YES. The conciliation procedure is not a jurisdictional requirement as expressly provided by Presidential
decree No. 1508. In line with this, the non-compliance to such cannot affect the jurisdiction which the lower
court had acquired over the subject matter of the case. Furthermore, the Certification to Filed an Action is
admissible. Section 34 of Rule 132 of the Rules on Evidence provides that the court cannot consider any
evidence that has not been formally offered. According to the cases of People vs. Napat-a, People vs. Mate, and
The Heirs of Romana Saves vs. The Heirs of Escolastico Saves, such requirement on the formal offer rule may
be relaxed which is subject to the following exceptions: first, the evidence must have been duly identified by
testimony duly recorded and, second, the evidence must have been incorporated in the records of the case. In
the present case, the requisites for the relaxation of the formal-offer rule are present. Godofredo identified the
Certification to File an Action during his cross-examination. Although the Certification was not formally offered
in evidence, it was marked as Exhibit 1 and attached to the records of the case which was neither objected nor
questioned by the petitioner.
b.) YES. The appreciation of the evidence was validly done since it was done in accordance with the exceptions
on the formal offer rule. On the other hand, the rejection of the claim for self-defense was done lawfully
because the petitioner did not substantiate it with clear and convincing proof. The most basic rule is that selfdefense can be recognized until unlawful aggression is established. The contention of the petitioner that
Godofredo attacked him was refuted by the prosecution witnesses presented in court and there was neither
presentation of medical certificate nor did he ever present a doctor he allegedly consulted. Hence, the court
validly convicted the petitioner because of the admissibility of the evidences and the failure to establish the
element of self defense.

Hence, the Supreme Court denied the appeal and affirmed the decision of the Court of Appeals.