G.R. No. 88183 - Astraquillo vs. Manglapus

The defendant, Genaro Pasca, was originally convicted of homicide and sentenced to twelve years and one day of reclusion temporal—the minimum penalty prescribed for that crime.
Though the defendant admitted to striking the fatal blow, he pleaded self-defense.
The judgment of conviction was rendered on February 19, 1912.
On March 12, 1912, the trial court set aside its former decision and entered a new judgment acquitting the defendant based on his claim of self-defense.
Upon the Government’s prayer, a writ of certiorari was issued, and this Court held that the trial court exceeded its jurisdiction in attempting to set aside a conviction rendered more than fifteen days after it was lawfully entered.
Consequently, the original judgment of conviction rendered on February 19, 1912, was held to remain in full force and effect.

Both the defendant and the deceased were owners of adjoining rice lands.
On the day in question, at about 6 o’clock in the evening, each was working on his respective parcel of land when a quarrel arose between them.
During the altercation, the defendant struck the deceased on the right temple with a bamboo pole approximately 7 feet long and as thick as a man’s arm, inflicting a wound that caused the deceased to die a few hours later without regaining consciousness.

The defendant testified that the deceased, while constructing a fence on the defendant’s land, provoked him.

He stated that after questioning the deceased’s act of building on his property, the deceased apparently rushed at him, pushing him into a shallow pool of water approximately knee-deep.
As he fell, the defendant claimed he grabbed a piece of bamboo floating in the water, adopted a half-sitting, half-rising posture, and delivered the fatal blow.
He further explained that he believed the deceased wished to kill him because he was being pushed into the water.

The boy, standing about 10 brazas away and facing away from his father and the defendant, initially testified that he only saw the fatal blow without hearing any altercation or quarrel.
Later, he added that he saw the defendant approach his father and deliver the blow without any words being exchanged.
His changing account raised doubts regarding his credibility.

A witness, Robert Panet, working not far from the scene, rushed to the area after hearing the cries of the deceased’s son and made exclamatory remarks upon his arrival, further adding color to the events.
The municipal board of health’s president examined the body shortly after the incident and corroborated that the fatal impact was the result of one single blow to the head.
Additional physical evidence noted that the deceased had his bolo, in its sheath, strapped under his shirt when he was struck.

The defendant's version of self-defense was scrutinized, with particular attention paid to the practicality of his explanations:

His assertion that he struck to escape from drowning in a shallow pool was questioned given the physical distances involved and the improbability of being in real danger of drowning.
His physical attributes (5 feet 2 inches in height and weighing only 110 pounds) were weighed against the feasibility of picking up a heavy bamboo pole and delivering a blow with “terrible force” from a half-sitting, half-rising position.

The trial judge’s later reasoning focused on the lack of credence in the testimony of the deceased’s son, whose observations were inconsistent with the defendant’s account of a quarrel that necessitated such a violent reaction.

Whether the trial court had the authority to set aside the judgment of conviction rendered on February 19, 1912, when the reversal occurred more than fifteen days after the original entry of judgment.

Whether the defendant’s plea of self-defense was supported by credible and consistent evidence.
The reliability of the deceased’s son’s testimony compared to that of the defendant and other witnesses.

Whether the elements required to justify self-defense were present, specifically:

Whether the provisions of Article 86 of the Penal Code, mandating reduction of penalties when mitigating circumstances are present, should be applied to the defendant’s case.