G.R. No. 8924 - People vs Rivera

A quarrel arose on December 27, 1912, in Vigan, Ilocos Sur, between the wife of the deceased, Cayetano Peralta, and the wife of defendant Domingo Rivera concerning the loan and non-return of a pair of scissors.
The verbal dispute escalated with heated and insulting language exchanged from adjacent houses, drawing the deceased into the confrontation.

Domingo Rivera, provoked by the dispute and having challenged Peralta with two stones in hand, called him out to prove his manhood.
Peralta, enraged by Rivera’s challenge and after allegedly making an offensive remark, armed himself with a large bolo and advanced from his house in response.

In the ensuing chase, Peralta inflicted two wounds on Rivera as he pursued him; Rivera then took refuge in a neighbor’s lot behind a fence.
While trapped by the fence, Rivera attempted to defend himself using what appeared to be a small knife or a very short bolo.
The intervention of co-accused Antonio Rivera (father of Domingo) and Canuto Batoon further escalated the melee; Antonio disarmed Peralta with a heavy piece of cane, and Batoon restrained him by catching him around the waist.

The record shows considerable conflict in witness accounts, notably between the testimony of the deceased’s widow and other witnesses.

The widow’s account inversely suggested that the deceased, armed with a large bolo, initiated the offense, and that all accused joined in the attack after Peralta retreated to the fence.
Other testimonies and physical evidence, including the size and nature of the bolo used by Domingo Rivera (a smaller weapon compared to the bolo described by the widow), cast doubt on the widow’s version of events.

The court inferred that the widow may have deliberately inverted the facts to increase the criminal liability of the accused.

Domingo Rivera eventually produced a small bolo (or knife) at trial, which was compared favorably against the larger weapon of the deceased, establishing that he was not initially armed with a bolo when he challenged Peralta.
The fatal blow was inflicted by Rivera, as corroborated by physical evidence, specifically the wounds on his back, indicating his attempt to escape the confrontation.

The charge against the defendants was homicide, with the original sentence of fourteen years, eight months, and one day of reclusion temporal, including accessory penalties.
The prosecution presented a narrative based mostly on the widow’s testimony, while the defense argued that the involvement of Antonio Rivera and Canuto Batoon was solely an act to save a kin from imminent danger, and that Domingo Rivera’s claim of self-defense was tainted by his provocation.

Whether Domingo Rivera’s claim of having acted in lawful self-defense is valid in light of his initial provocation of the deceased.
The extent to which the provocation affects the applicability of absolute self-defense as provided by Article 8 of the Penal Code.

Whether Antonio Rivera and Canuto Batoon, who intervened during the confrontation, acted only out of a desire to protect their kinsman and friend, thereby qualifying for exemption from criminal liability.
The evaluation of their actions in light of the necessary elements constituting self-defense.

How to reconcile conflicting witness statements, particularly the discrepancies between the widow’s testimony and that of other witnesses.
Assessing the consistency and inherent probability of the evidence regarding the sequence of events leading to the fatality.