Case Digest (G.R. No. L-55487)
Facts:
The case involves Domingo Banasen as the defendant-appellant and the People of the Philippines as the plaintiff-appellee. The events transpired on December 2, 1979, in Uyong, Labrador, Pangasinan. The prosecution's evidence indicated that at around 2:00 AM, Leonardo Malong was attacked by Domingo Banasen with a bolo while Malong was with Nemesio Gonzales, who had stopped to relieve himself. Gonzales witnessed the attack and ran to inform Barangay Captain Buenaventura Arenas. Upon their return, they found Malong dead in a yard, approximately 30 to 40 meters from Banasen's house. The police were notified, and upon investigation, they discovered bloodstains at the scene and in Banasen's home.
Banasen was later found hiding in a "boho" grove, where he surrendered to the police and admitted to killing Malong. He claimed self-defense, asserting tha...
Case Digest (G.R. No. L-55487)
Facts:
Prosecution's Version
- On December 2, 1979, at around 2:00 AM, Leonardo Malong and Nemesio Gonzales were on their way to buy "boho" in Loob, Uyong, Labrador, Pangasinan.
- Nemesio Gonzales stopped to answer a call of nature, while Leonardo Malong walked ahead.
- Domingo Banasen suddenly appeared and hacked Leonardo Malong with a bolo, killing him.
- Nemesio Gonzales ran to Barangay Captain Buenaventura Arenas to report the incident.
- Martha Banasen, Domingo's wife, arrived and revealed that Domingo and Leonardo were fighting.
- The Barangay Captain and Nemesio Gonzales returned to the scene and found Leonardo Malong dead in a yard, soaked in blood.
- Police investigators found bloodstains and skull fragments at the scene, as well as bloodstains on the flooring of Domingo Banasen's house.
- Domingo Banasen was found hiding in a "boho" grove, surrendered his bolo, and admitted to killing Leonardo Malong.
Defense's Version
- Domingo Banasen claimed he killed Leonardo Malong in defense of himself and his wife's honor.
- He testified that upon arriving home, he heard his wife crying and found Leonardo Malong atop her.
- Leonardo Malong drew a bolo and attacked Domingo, wounding him on the left hand and knee.
- Domingo retaliated, hacking Leonardo Malong multiple times, leading to his death.
- Domingo dragged Leonardo's body to a nearby yard to prevent it from being trampled.
- He intended to surrender but was apprehended by police before he could do so.
Physical Evidence
- Bloodstains were found inside Domingo Banasen's house, on the porch, stairs, and surrounding areas, corroborating his claim that the fight started inside the house.
- A hat belonging to Leonardo Malong was found near the kitchen, supporting Domingo's claim that Leonardo's hat flew off during the struggle.
- Domingo Banasen suffered incised wounds on his hand and knee, consistent with his claim of being attacked by Leonardo Malong.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Unlawful Aggression: The Court found that Leonardo Malong initiated the aggression by attacking Domingo Banasen with a bolo after being caught in the act of assaulting Domingo's wife.
- Reasonable Necessity of Means: Domingo Banasen used a bolo to defend himself and his wife, which was deemed reasonable given the circumstances.
- Lack of Provocation: Domingo Banasen did not provoke the attack and had no part in the initial aggression.
- Physical Evidence: The bloodstains inside the house, the presence of Leonardo Malong's hat, and Domingo's wounds corroborated his version of events.
- Credibility of Witnesses: The inconsistencies in the testimony of prosecution witness Nemesio Gonzales and the lack of corroboration for his version of events weakened the prosecution's case.
- Self-Defense and Defense of Honor: The Court ruled that Domingo Banasen acted in defense of his wife's honor and in self-defense, exempting him from criminal liability.
The Court emphasized that Domingo Banasen's actions were justified under the circumstances, and he incurred no criminal responsibility.