Criminal’s normal predisposition to ensure execution in way least expected

There is nothing unusual in the manner of assaulting a person even if no altercation between the victim and the assailant immediately preceded the attack. In fact, judicial notice can be taken of the normal predisposition of those with criminal intent to execute their sinister plan in a way least expected in order to insure it execution. in this case, knowing that Sabino was then carrying a bolo, appellant Nestor Escandor suddenly and without any warning shot Sabino from behind. The execution of the appellant's plan was achieved with greater ease and without risk to themselves. [G.R. No. 95049. December 9, 1996]