G.R. No. L-52245 - Dumlao vs. Commission on Elections

On February 12, 2012, in Roxas, Zamboanga del Norte, 29-year-old laborer Rulie Compayan Camillo was delivering sacks of rice at his employer’s store.
Noel Angcla, a 50-year-old intoxicated man, unprovokedly struck Rulie twice—first while Rulie carried a sack of rice, then again moments later. Rulie dropped the sack and punched Noel on the nose and jaw. Noel fell onto the concrete pavement, suffering fatal head injuries.

Rulie was charged with homicide under Article 249 of the Revised Penal Code, alleged to have attacked Noel with intent to kill and without justifiable cause.
The Regional Trial Court convicted him of homicide and imposed an indeterminate sentence of ten years of prisión mayor as minimum to fourteen years, eight months, and one day of reclusion temporal as maximum, and awarded ₱50,000 civil indemnity and ₱50,000 moral damages.
On appeal, the Court of Appeals affirmed the conviction, modified damages to ₱50,000 civil indemnity, ₱50,000 moral damages, and ₱50,000 temperate damages, and ordered the cancellation of his bail bond.
Rulie filed a petition for review on certiorari with the Supreme Court, invoking self-defense as a justifying circumstance.

Whether Rulie validly invoked the justifying circumstance of self-defense by establishing unlawful aggression on the part of Noel.
Whether the means employed by Rulie—the use of his fists—were reasonably necessary to repel the alleged aggression.
Whether Rulie lacked sufficient provocation, a requisite for a plea of self-defense.