Case Summary (G.R. No. 260353)
Petitioner
Rulie Compayan Camillo, convicted by the Regional Trial Court of homicide and affirmed by the Court of Appeals.
Respondent
People of the Philippines.
Key Dates
- February 12, 2012: Incident date.
- October 22, 2018: Trial court conviction.
- December 11, 2020: Court of Appeals Decision.
- February 21, 2022: Court of Appeals Resolution.
- February 8, 2023: Supreme Court Decision.
Applicable Law
- 1987 Philippine Constitution (post-1990 decision)
- Revised Penal Code, Article 11(1) (self-defense), Article 4(1) (liability for unintended results), Article 249 (homicide)
Facts
While carrying a heavy sack of rice, Rulie was boxed twice without provocation by an intoxicated Noel. Feeling threatened, Rulie dropped the sack and delivered a powerful punch to Noel’s nose and jaw. Noel fell backward onto the pavement and died shortly thereafter.
Procedural History
- Trial court found absence of justifying circumstance, ruled Rulie acted in retaliation, and convicted him of homicide (prision mayor to reclusion temporal). Civil indemnity and moral damages of ₱50,000 each were imposed.
- Court of Appeals affirmed the conviction but granted temperate damages of ₱50,000 and canceled Rulie’s bail, ordering his arrest.
- Rulie elevated the case by petition for review on certiorari to the Supreme Court.
Issue
Whether Rulie’s act constituted homicide or was justified under self-defense.
Rulings of Lower Courts
- Trial court: No unlawful aggression at time of fatal blow; defense was retaliatory.
- Court of Appeals: Aggressor’s intoxication and physical state negated imminent threat; means employed by Rulie disproportionate.
Legal Analysis: Self-Defense
Unlawful Aggression
- Defined as a real, material, or imminent threat to life or personal safety.
- Assessed from the accused’s perspective under the circumstances as they reasonably appeared to him.
- Persistent and reckless fist blows by a drunken aggressor constitute unlawful aggression.
Reasonable Necessity of Means Employed
- The force used must correspond to the nature and urgency of the threat.
- In sudden confrontations, instinct for self-preservation may override calm reflection; only reasonable defensive force is required.
- Two punches to Noel’s face, delivered to repel further unprovoked attacks, met this standard.
Lack of Sufficient Provocation
- Provocation must come from the defendant’s unjust or improper conduct.
- Rulie did not provoke Noel; he was attacked while performing his duties.
Supreme Court Ruling
The Supreme Court reversed and acquitted Rulie, holding that:
- Unlawful aggression by Noel persisted until the moment of the defensive blow.
- Rulie’s use of fist blows was a rational response to an imminent threat posed by a larger, intoxicated assailant.
- No sufficient provocation originated from Rulie to justify Noel’s assault.
- Self-defe
Case Syllabus (G.R. No. 260353)
Facts of the Case
- On February 12, 2012, in the Municipality of Roxas, Zamboanga del Norte, petitioner Rulie Compayan Camillo (“Rulie”) was carrying a sack of rice at his employer’s store.
- Respondent Noel Angcla (“Noel”), intoxicated at the time, suddenly boxed Rulie once, then boxed him again while Rulie was still carrying the rice.
- Rulie put down the sack of rice and punched Noel on the nose and jaw.
- Noel fell backward onto the concrete pavement and sustained fatal head injuries, leading to his death shortly thereafter.
Procedural History
- Rulie was charged with homicide under Article 249 of the Revised Penal Code, alleged to have acted “with intent to kill and without justifiable cause or sufficient provocation.”
- At trial, Rulie pleaded self-defense. The Regional Trial Court (RTC), Branch 6, Dipolog City, convicted him of homicide and imposed an indeterminate sentence of ten years of prision mayor (minimum) to fourteen years, eight months, and one day of reclusion temporal (maximum), plus civil indemnity, moral damages, and costs.
- Rulie appealed to the Court of Appeals-Cagayan de Oro City (CA) under CA-G.R. CR No. 01826-MIN. The CA affirmed his guilt for homicide but modified the damage awards to include temperate damages and ordered his immediate arrest for service of sentence.
- Rulie filed a petition for review on certiorari before the Supreme Court, contending that he acted in lawful self-defense.
Issue
- Whether the killing of Noel Angcla by Rulie Compayan Camillo w