G.R. No. 181071 - EspiNo. vs. People

On 6 August 2000 at approximately 10 o’clock in the evening, private complainant Andy Merto, harboring a grudge against petitioner Ladislao Espinosa, went to Espinosa’s residence in the Municipality of Sta. Cruz, Zambales.
While outside the house, Merto aggressively shouted violent threats challenging Espinosa to face him.

Sensing Merto’s agitated state and fearing for his family’s safety, Espinosa emerged from his house to deescalate the confrontation.
As Espinosa approached, Merto hurled a stone at him; the petitioner managed to dodge the projectile and, in an act of instinctive retaliation, struck Merto’s left leg with a bolo scabbard.

After the initial strike, Merto was forced to the ground as Espinosa continued to attack him with the bolo scabbard, engaging in what was described as “continuous hacking.”
The assault was only halted when Merto’s cousin, Rodolfo Muya, intervened to restrain Espinosa.

As a direct outcome of the incident, Merto sustained two bone fractures: one in his left leg and another in his left wrist.
It required approximately six months for Merto to fully recover from these injuries.

Initially, on 22 September 2000, Espinosa was charged with Frustrated Homicide under an Information alleging a series of violent attacks with improper intent to kill, as the detailed facts mentioned various hacking wounds and medical interventions.
During trial on 14 December 2004 at the Regional Trial Court of Iba, Zambales, Branch 71, the court convicted Espinosa of Serious Physical Injuries under the third paragraph of Article 263 of the Revised Penal Code, noting the lack of evidence proving an intent to kill.
Espinosa was sentenced to suffer six (6) months of Arresto Mayor and was ordered to pay Merto actual damages amounting to P54,925.50.

Espinosa filed a Motion for Reconsideration on 7 February 2005, invoking a complete self-defense claim under the first paragraph of Article 11 of the Revised Penal Code.
The trial court, in its Resolution dated 30 March 2005, denied the motion, holding that the manner and extent of Espinosa’s actions were not reasonably necessary to qualify as self-defense.
The Court of Appeals later affirmed the trial court’s conviction but modified the penalty in recognition of a privileged mitigating circumstance (incomplete self-defense under Article 69 of the Revised Penal Code) and similarly denied the petitioner’s motion for reconsideration.
Subsequently, Espinosa elevated the case to the Supreme Court via a Petition for Review on Certiorari under Rule 45, challenging the failure to appreciate complete self-defense.

Whether, based on the set of facts presented in the case, the element of complete self-defense can be appreciated in favor of petitioner Ladislao Espinosa.
Whether the means adopted by Espinosa in repelling the attack, particularly his use of continuous hacking even after the victim had been neutralized, meet the criteria of “reasonable necessity” under the justifying circumstance of self-defense.