When an accused invokes self-defense, the burden
of proof to show that the killing was justified shifts to him. Even
if the prosecution evidence may be weak, it could not be disbelieved after his
open admission owing authorship of the killing. However, to
implicate a co-accused as a co-principal, conspiracy must be proven beyond
reasonable doubt. In the absence of conspiracy, the responsibility
of the two accused is individual, not collective. Otherwise stated, when the
accused invoke self-defense, the burden of proof is shifted to them to prove
that the killing was justified and that they incurred no criminal liability
therefor. They must rely on the strength of their own evidence and
not on the weakness of that of the prosecution, for even if the latter is weak,
it could not be disbelieved after their open admission of responsibility for
the killing. (People vs. Tan, G.R. No.
132324, September 28, 1999, Panganiban, J.).
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