Case Digest (G.R. No. 15697)
Facts:
The case involves Mariano Singson as the appellant and the United States as the plaintiff and appellee. The events transpired on June 23, 1919, near the residence of Jose Solla, who claimed ownership of a bamboo thicket. Singson, accompanied by three armed men, entered the thicket to cut bamboo, allegedly under the direction of Roman Bermudez, Singson's brother-in-law and the bamboo's owner. However, Solla disputed this claim and confronted Singson, demanding to know the authority under which the bamboo was being cut. A verbal altercation ensued between Solla and Singson. Shortly thereafter, Solla was found fatally wounded approximately 70 to 80 meters from the initial confrontation. Before dying, Solla made a statement to a justice of the peace, accusing Singson and his companions of murder. The prosecution argued that Singson shot Solla with a revolver and that his group attacked Solla with bolos, leading to his death. Conversely, the defense claimed that Solla atta...
Case Digest (G.R. No. 15697)
Facts:
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.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.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.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.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:
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.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.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.Aggravating Circumstance:
The Court found the aggravating circumstance of superior force, as Singson and his companions outnumbered and overpowered Solla.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.