Facts:

The case involves George Washington as the defendant and the United States as the complainant and appellee. The events took place on April 29, 1903, at Bilibid Prison in Manila. Washington was convicted by the Court of First Instance for assaulting H.S. Harris, another prisoner, with a deadly weapon, specifically a large club. The assault resulted in injuries to Harris, causing him illness and disability for over thirty days. Consequently, Washington was sentenced to one year of imprisonment and ordered to pay the costs associated with the case.

Prior to this incident, Washington had been sentenced to serve three years in prison due to a charge related to his service as a soldier in the Ninth Cavalry of the United States Army. During his previous incarceration, he was responsible for mixing cement and overseeing its use, under the direction of the master mechanic. On the day of the incident, while Washington was temporarily away from the cement bed, Harris attempted to tak...

Facts:

1. Incident Details:

   • On April 29, 1903, at Bilibid Prison in Manila, George Washington, the defendant, assaulted and beat H.S. Harris with a large club (a bamboo stick as thick as his wrist).
   • The assault caused injuries to Harris, resulting in illness and disability for more than thirty days.

2. Background of the Defendant:

   • George Washington was already serving a three-year sentence in Bilibid Prison for a prior charge while serving as a soldier in the Ninth Cavalry, U.S. Army.
   • As a prisoner, he was assigned to oversee the mixing and care of cement and was instructed by the master mechanic not to allow anyone to take cement without proper authorization.

3. Trigger of the Altercation:

   • While Washington was temporarily away from the cement bed, Harris attempted to take cement without authorization.
   • Upon returning, Washington confronted Harris, leading to a verbal altercation. Harris resented Washington's words and struck the first blow.

4. Escalation of the Fight:

   • Harris attempted to grab a shovel to inflict more damage.
   • Washington picked up a bamboo stick and struck Harris across the back.
   • The fight was temporarily stopped, but Harris attempted to strike Washington again.
   • Washington ran, picked up bricks or rocks, and threatened to throw them but did not follow through.

5. Aftermath:

   • Harris was hospitalized for about a month.
   • Washington was placed in "the guardelo, the dark cell, the place of punishment" for breaching prison discipline.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Provocation by the Victim:

   • Harris was the aggressor, having provoked the altercation by attempting to take cement without authorization and striking the first blow.

2. Nature of Injuries:

   • Harris's injuries, while resulting in a month-long hospitalization, were not deemed serious enough to warrant criminal liability for Washington.

3. Defendant's Conduct and Character:

   • Washington had a good reputation and was a well-behaved prisoner.
   • He had already been punished for breaching prison discipline by being placed in the dark cell.

4. Self-Defense and Proportionality:

   • Washington's actions were seen as a response to Harris's aggression and were not disproportionate under the circumstances.

The Court concluded that the defendant should not be held criminally liable given the provocation by Harris, the nature of the injuries, and Washington's prior punishment for prison discipline.