G.R. No. 221697 - Poe-Llamanzares vs. Commission on Elections

The incident occurred on the morning of May 12, 1924, in barrio Moson of the municipality of San Luis, Province of Batangas.
A quarrel arose between the accused, Casimiro Panganiban, and Marcelo Garcia, who was the deceased.
Prior to the altercation, Marcelo Garcia had initiated a debt collection effort by sending his sister Rosario to the accused’s residence to demand payment of a sum owed.
It is noted that a few days earlier, Marcelo Garcia also had an altercation with the accused’s son, though the reasons for this were not detailed in the record.

Marcelo Garcia, while at the accused’s house, entered into a quarrel with Casimiro Panganiban.
The deceased claimed that he was attacked by the accused:

He stated that a bamboo stick, known locally as “pinga,” was used to strike his hand.
Subsequently, he sustained a fatal wound in the abdomen caused by a penknife.

The accused admitted to wounding Marcelo Garcia but maintained that his actions were in self-defense against the aggression of Marcelo.

Marcelo Garcia drew a penknife from behind his back and pressed an attack, forcing the accused to react.
In response, the accused caught hold of the deceased’s right wrist with his right hand and gripped the corresponding forearm with his left hand.

The accused’s control over the deceased’s limb temporarily neutralized the immediate threat, as the hand holding the penknife was immobilized.
However, as the deceased persisted with his attack, the accused, fearing for his personal safety, redirected the penknife—originally in the deceased’s hand—towards him, resulting in wounds that led to the deceased’s death later that same day.

The testimony of local witnesses, including the deceased’s account to the local chief of police, played a significant role in establishing the facts.
The absence of eyewitness testimony to the beginning of the quarrel meant that:

The court was compelled to give the accused the benefit of the doubt.
It was accepted as fact that the deceased was armed with a penknife and had instigated the confrontation.

Initially, the accused’s actions were directed at neutralizing the threat posed by the deceased’s attack.
However, at the critical moment, when Marcelo Garcia still continued to struggle:

The accused’s act of directing the penknife against the deceased shifted the nature of his response.
This decisive act signified the commencement of criminal intent as it went beyond mere defense.

Whether the accused, Casimiro Panganiban, employed reasonable means in repelling the aggression initiated by Marcelo Garcia.
Whether the shift from self-defensive actions to an offensive maneuver (i.e., directing the penknife against the deceased) nullified the self-defense claim.
If the circumstances of the struggle justified the accused’s decision to control and then repurpose the deceased’s own weapon against him.
The applicability of established doctrines and precedents, particularly regarding the limits of self-defense under the law, in assessing the accused’s conduct.