Facts:

• On the night of January 2, 1909, Rafael Bumanglag discovered that 40 bundles of palay had been stolen from his granary in San Nicolas, Ilocos Norte.
• The next morning, Bumanglag found the stolen palay in a nearby sugar cane field, about 100 meters from his granary.
• To catch the thief, Bumanglag, along with Gregorio Bundoc, Antonio Ribao, and Saturnino Tumamao, decided to stake out the field that night.
• Around 10 PM, Guillermo Ribis appeared and attempted to take the palay.
• Bumanglag and his companions attacked Ribis with sticks and cutting weapons, resulting in Ribis's death.
• Believing Ribis to be responsible for several local thefts, the group acted without any legal authority.
• The provincial fiscal filed a homicide charge against Bumanglag, Bundoc, and Ribao on January 15, 1909.
• The trial court sentenced them to fourteen years, eight months, and one day of reclusion temporal, along with an indemnity of P1,000 to Ribis's heirs.
• Only Gregorio Bundoc appealed the decision.

Issue:

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Ruling:

• The court ruled that there was no unlawful aggression by Guillermo Ribis that justified the plea of self-defense by Gregorio Bundoc.
• The court found that the actions of Gregorio Bundoc and his companions were not reasonably necessary to prevent or repel any alleged aggression.
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Ratio:

• The court determined that the plea of self-defense was not admissible because there was no evidence of unlawful aggression by Ribis.
• The bolo found in its sheath on Ribis's body indicated that he had not attacked Bumanglag and his companions.
• The court noted that the serious wounds inflicted on Ribis were consistent with the use of cutting and stabbing weapons, contradicting the defendants' claim that they only used sticks.
• Given these facts,...continue reading