Case Digest (G.R. No. 22557)
Facts:
The People of the Philippine Islands v. Zacarias Ragaza (alias Paye), G.R. No. L-22557. September 27, 1924, the Supreme Court, Villamor, J., writing for the Court. The plaintiff-appellee was The People of the Philippine Islands; the defendant-appellant was Zacarias Ragaza (alias Paye); a co-accused, Domingo Quiquilat, was also charged.The Court of First Instance of Oriental Negros tried the case on a complaint charging Ragaza and Quiquilat with the homicide of Pelagio Quinamot. The trial judge found that on or about January 24, 1924 at barrio Atimo, municipality of Siaton, Pelagio, his wife Dominga and son Alfonso were near a domestic fire when the defendants arrived. The prosecution witnesses and the deceased’s family testified that Ragaza asked for buyo and immediately struck Pelagio with a lance; the body was later found with the lance driven side to side through the corpse.
Ragaza admitted killing Pelagio but asserted lawful self-defense, testifying that an altercation began when Alfonso disturbed the fire, Pelagio slapped Alfonso and subsequently mounted and held Ragaza down for about an hour; Ragaza claimed Pelagio left to fetch a bolo and, as Pelagio returned, Ragaza took his lance and wounded him at a distance of about one braza. Ragaza exhibited a scar on his right knee and introduced a certificate of autopsy (Exhibit 1) showing three deep incised wounds penetrating the abdominal and chest cavities.
The trial court rejected Ragaza’s account as improbable and unsupported by corroboration, found the quantity and severity of the wounds indicative of cruelty rather than defensive action, convicted Zacarias Ragaza of homicide and sentenced him to twelve years’ reclusion temporal, ordered P500 indemnity to the heirs, and acquitted Domingo Quiquilat. Ragaza appealed to the Supreme Court.
On appeal to the Supreme Court, the Court reviewed the testimony and evidence. The Supreme Court found no basis to overturn the trial court’...(Subscriber-Only)
Issues:
- Did Zacarias Ragaza act in lawful self-defense so as to negate criminal liability for the homicide of Pelagio Quinamot?
- If convicted, should the penalty imposed by the trial court be...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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