Facts:

The case involves Ponciano Esmedia and Mena Esmedia as defendants and appellants against the United States as the plaintiff and appellee. The events transpired on June 24, 1909, in the barrio of Bongbongan, Sibalom, Province of Antique, Philippines. The Esmedia family and the Abando family had a longstanding dispute over the ownership of rice land occupied by Ciriaco Abando, the patriarch of the Abando family. On the day of the incident, Ciriaco instructed his son, Santiago, to manage the water in their rice field. While Santiago was performing this task, Gregorio Esmedia, the father of the accused, confronted him, leading to a violent altercation where Gregorio stabbed Santiago in the back. Santiago retaliated with a bolo, inflicting wounds on Gregorio.

Ponciano and Mena Esmedia, upon witnessing their father being attacked, rushed to his aid. Ponciano claimed that he was attacked by Ciriaco and Santiago, leading him to defend himself. The confrontation escalated, resultin...

Facts:

Background and Relationship Between Parties

• Ciriaco Abando, his wife, and their son, Santiago Abando, lived in the barrio of Bongbongan, Province of Antique.
• Gregorio Esmedia, father of the accused Ponciano and Mena Esmedia, was the son-in-law of Ciriaco Abando and brother-in-law of Santiago Abando.
• The two families lived near each other and owned adjoining rice lands. There had been a prior dispute over the ownership of the rice land occupied by Ciriaco Abando.

The Incident

• On June 24, 1909, at around 2:00 PM, Ciriaco instructed his son Santiago to let out water from their rice field for planting.
• While Santiago was working, Gregorio Esmedia arrived and started a quarrel with him. Gregorio drew a dagger and stabbed Santiago in the back.
• Santiago retaliated with his bolo, inflicting fatal wounds on Gregorio.
• Ponciano and Mena Esmedia arrived at the scene. They claimed they were working nearby and rushed to assist their father, Gregorio.
• Ponciano contended that he was attacked by Ciriaco and Santiago, and he defended himself using a club, not a bolo.
• The prosecution argued that Ponciano and Mena killed Santiago and Ciriaco outright.

Injuries and Deaths

• Ciriaco Abando: Sustained multiple fatal wounds, including two on the head, a fractured skull, and other injuries caused by a cutting instrument.
• Santiago Abando: Received seven wounds, including deep cuts on the head and neck, inflicted by a sharp instrument.
• Gregorio Esmedia: Suffered four wounds, including a fatal stab wound inflicted by Santiago.
• Ponciano Esmedia: Received a minor head wound, while Mena Esmedia was uninjured.

Witness Testimonies

• Andrea Lactoson (Ciriaco’s wife) and Julian Alagos (Ciriaco’s grandson) testified about the fight. Their testimonies were somewhat contradictory but confirmed the presence of the accused at the scene.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Defense of a Relative: Under Article 8, No. 5 of the Penal Code, the accused were justified in killing Santiago Abando to defend their father, Gregorio, who was fatally wounded and in imminent danger.
2. Lack of Provocation: The killing of Ciriaco Abando was not justified, as he arrived after the fight had ended and posed no threat or provocation to the accused.
3. Aggravating and Mitigating Circumstances: The court considered the disregard for Ciriaco’s age as an aggravating circumstance but balanced it with the mitigating circumstance of the accused’s ignorance.
4. Extenuating Circumstances: The court ruled that the provocation by Santiago could not be extended to justify the killing of Ciriaco, as Ciriaco had no involvement in the initial altercation.