Case Digest (G.R. No. 6372)
Facts:
The case involves Pascual Molina as the defendant and the United States as the plaintiff. The events took place in the Philippines, culminating in a judgment rendered by the Court of First Instance on March 27, 1911. Pascual Molina was convicted of homicide for the death of Francisco Gaspar and was sentenced to 12 years and 1 day of reclusion temporal, along with an indemnity of P1,000 to the heirs of the deceased and the costs of the trial. The prosecution's case was based on the testimony of the deceased's wife and daughter, who claimed that Molina attacked Gaspar from behind without provocation, inflicting fatal wounds with a bolo. In contrast, Molina's defense asserted that he was invited to the deceased's house to resolve a family dispute regarding their children, and upon arrival, he was assaulted by Gaspar, who was armed with a bolo. Molina claimed he acted in self-defense after disarming Gaspar, who then attempted to attack him ag...
Case Digest (G.R. No. 6372)
Facts:
Background of the Crime:
- The accused, Pascual Molina, was convicted of homicide for killing Francisco Gaspar. He was sentenced to 12 years and 1 day of reclusion temporal, an indemnity of P1,000 to the deceased's heirs, and payment of trial costs.
- The accused admitted to inflicting the fatal wounds but contested the circumstances under which the crime occurred.
Prosecution's Version:
- The wife and daughter of the deceased testified that the accused, accompanied by his sister Filomena Molina and brother-in-law Santiago Elseco, approached the deceased from behind while he was sitting on the ground. Without provocation, the accused attacked the deceased with a bolo, causing fatal wounds.
Defense's Version:
- The accused claimed that his son, Sabino Molina, and the deceased's daughter, Agapita Gaspar, had been living together as husband and wife with both families' consent. After a dispute, Sabino was expelled from the deceased's house.
- The deceased's wife invited the accused to their house to settle the matter. Upon arrival, the deceased insulted and attacked the accused with a bolo. The accused, unarmed, wrestled the bolo from the deceased and used it to defend himself, inflicting fatal wounds.
Trial Court's Findings:
- The trial court found the defense's version more credible, noting that the accused was unarmed and acted in self-defense. However, it concluded that the accused used excessive force, as the deceased was unarmed and at the accused's mercy after being disarmed.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Self-Defense:
- The Court found that the deceased was the aggressor and that the accused was unarmed at the time of the assault. The deceased's aggressive behavior continued even after the accused disarmed him, as he attempted to seize a hatchet to continue the attack.
Rational Necessity of Means:
- The Court rejected the trial court's conclusion that the accused used excessive force. It emphasized that the danger to the accused's life persisted throughout the struggle, and he was not obligated to flee or risk further harm. The use of the bolo to disable the deceased was deemed necessary to repel the ongoing assault.
Exemption from Criminal Liability:
- The Court applied Article 8, paragraph 4 of the Penal Code, which exempts from criminal liability those who act in self-defense against an unlawful aggression, provided the means employed are rationally necessary. The accused's actions met these criteria, and he was therefore acquitted.