Title
People vs Singson
Case
G.R. No. 15697
Decision Date
Sep 6, 1920
Mariano Singson, accused of homicide, claimed self-defense after a fatal altercation over bamboo ownership. The Supreme Court reversed his acquittal, finding excessive force and use of a firearm, sentencing him to 17+ years.
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Case Digest (G.R. No. 15697)

Facts:

  1. Incident Overview:
    On June 23, 1919, Mariano Singson led a group of armed men to cut bamboo near Jose Solla's house. Singson claimed he acted under the direction of Roman Bermudez, his brother-in-law, who allegedly owned the bamboo. However, Solla also claimed ownership of the bamboo and confronted the group.

  2. Altercation and Death:
    Solla ordered the men to stop cutting the bamboo and demanded an explanation. Singson and Solla exchanged words, and shortly after, Solla was found fatally wounded about 70-80 meters away. He died hours later but made a statement accusing Singson and his companions of murder.

  3. Prosecution's Version:
    The prosecution alleged that Singson fired a revolver at Solla, and his companions attacked Solla with bolos. Solla attempted to flee but was overtaken and killed.

  4. Defense's Version:
    The defense claimed Solla attacked Singson with a bolo, forcing Singson to defend himself. Singson testified that he acted in self-defense, sustaining injuries during the altercation. He denied using a revolver and stated his companions did not participate in the attack.

  5. Trial Court's Decision:
    The trial judge acquitted Singson's companions but convicted Singson of homicide, sentencing him to eight years and one day of prision mayor. The judge found that Singson acted in self-defense but exceeded the necessary force.

Issue:

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Ruling:

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Ratio:

  1. Credibility of Witnesses:
    The Supreme Court found the prosecution's witnesses, including the dying declaration of Solla and his widow's testimony, more credible than the defense's version. The discovery of Solla's blood-stained and bolo-slashed hat near the altercation site corroborated the prosecution's account.

  2. Use of Firearm:
    The Court held that Singson fired a revolver at Solla, as stated in Solla's dying declaration and corroborated by his widow. This contradicted Singson's claim of self-defense without the use of a firearm.

  3. Excessive Force:
    The Court ruled that Singson exceeded the bounds of rational necessity in defending himself. The seven bolo wounds inflicted on Solla indicated excessive force, disproving Singson's claim of proportionate self-defense.

  4. Aggravating Circumstance:
    The Court found the aggravating circumstance of superior force, as Singson and his companions outnumbered and overpowered Solla.

  5. No Exempting Circumstances:
    The Court rejected Singson's plea of self-defense, holding that the evidence did not support his claim of acting solely in self-defense.


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