G.R. No. 260353 - Camillo vs. People

Case Summary (G.R. No. 260353)

Factual Background

On February 12, 2012, while carrying a sack of rice and performing his work, petitioner Rulie was suddenly boxed by Noel, who was intoxicated. After being boxed twice while carrying sacks, Rulie set the sack down and punched Noel on the nose and jaw. Noel fell, struck the concrete pavement, and died shortly thereafter. Eyewitnesses testified that Noel continued attacking Rulie after the first and second sacks were set down.

Criminal Charge and Plea

Petitioner was charged with homicide under Article 249 of the Revised Penal Code, accused of attacking and boxing Noel with intent to kill and without justifiable cause or sufficient provocation. Petitioner pleaded self-defense.

Trial Court Findings and Sentence

The Regional Trial Court (Branch 6, Dipolog City) rejected the self-defense plea, concluding petitioner acted in retaliation rather than in defense. The trial court convicted him of homicide and imposed an indeterminate sentence (minimum ten years prision mayor to maximum fourteen years, eight months, and one day reclusion temporal) and ordered payment of civil indemnity (₱50,000), moral damages (₱50,000), and costs.

Court of Appeals Decision and Reasoning

On appeal, the Court of Appeals (Cagayan de Oro) affirmed the conviction but modified damages, awarding civil indemnity and moral damages of ₱50,000 each and temperate damages of ₱50,000, all with six percent interest from finality. The CA held unlawful aggression was absent or had ceased by the time petitioner struck Noel, reasoning that petitioner retaliated after the aggression had ended. The CA also emphasized the disparity in physical condition—Noel being intoxicated, older, and less physically capable, and petitioner being a sober, younger laborer—and concluded the means employed by petitioner were not reasonably commensurate to the threat.

Issue on Review

Whether petitioner established the justifying circumstance of self-defense and, consequently, whether he should be acquitted of the homicide charge and relieved of civil liability.

Legal Standard on Self-Defense and Burden of Proof

The Court reiterated the statutory and doctrinal elements of self-defense under Article 11(1) of the Revised Penal Code: (1) unlawful aggression on the part of the victim; (2) reasonable necessity of the means employed to prevent or repel such aggression; and (3) lack of sufficient provocation by the person invoking self-defense. Where the accused admits the act but pleads self-defense, the burden shifts to the accused to clearly establish the justifying circumstance by convincing evidence; the accused’s perception of danger, viewed from his standpoint at the time, is central.

Supreme Court’s Analysis — Unlawful Aggression

The Court disagreed with both the trial court and the CA, emphasizing that unlawful aggression must be evaluated from petitioner’s perspective at the moment of the confrontation. Noel’s intoxication and persistent, taunting physical blows constituted a real, imminent, and actual danger in the circumstances as perceived by petitioner. The Court noted eyewitness testimony that Noel continued to attack after petitioner set down the sacks, and underscored that impatience, recklessness, and intoxication can compound the imminence and severity of aggression. The Court rejected the expectation of judicial composure as the standard for a person under immediate assault.

Supreme Court’s Analysis — Reasonable Necessity of the Means Employed

The Court found that petitioner employed only his fists (two blows to the face) to repel the assault, which evidenced an intent to stop the attack rather than to kill. The Court recognized the role of the instinct of self-preservation and that in the heat of an attack an accused cannot be expected to exercise calm, measured calculation; what matters is whether the accused reasonably believed the force used was necessary. Given petitioner’s limited use of force and the context of ongoing physical assault by a drunk aggressor, the Court concluded the means were reasonably necessary to repel the aggression. The Court also reiterated the mens rea principle (actus non facit reum nisi mens sit rea) and found no criminal intent in petition

Case Syllabus (G.R. No. 260353)

Case Caption, Court and Decision

Second Division, Supreme Court of the Philippines; G.R. No. 260353; Decision promulgated February 08, 2023.
Title as presented in the source: "RULIE COMPAYAN CAMILLO, * PETITIONER , VS. PEOPLE OF THE PHILIPPINES, RESPONDENT ."
Decision authored by Justice M. Lopez; concurring Justices Leonen (SAJ, Chairperson), Lazaro-Javier, and Kho, Jr.
The Court granted the Petition for Review on Certiorari, reversed the Court of Appeals-Cagayan de Oro City Decision dated December 11, 2020 and its Resolution dated February 21, 2022 in CA-G.R. CR No. 01826-MIN, acquitted Rulie Compayan Camillo of homicide, and ordered his immediate release unless lawfully held for another cause.

Factual Background

On February 12, 2012, petitioner Rulie Compayan Camillo (hereafter "Rulie") worked delivering sacks of rice for his employer in Olingan, Dipolog City; the incident occurred in the Municipality of Roxas, Zamboanga del Norte.
While carrying a sack of rice, Rulie was suddenly boxed by one Noel Angcla (hereafter "Noel"), who was drunk at the time.
Noel boxed Rulie again while Rulie continued working; Rulie then put down the sack and punched Noel on his nose and jaw.
Noel fell and hit the concrete pavement; he died shortly thereafter.
Eyewitnesses testified that Noel did not stop attacking Rulie after Rulie put down the first and second sacks of rice, and that Noel remained in a fighting stance until Rulie struck him.

Criminal Charge and Trial Court Disposition

Rulie was charged with homicide under Article 249 of the Revised Penal Code with allegation that on or about February 12, 2012, in Roxas, Zamboanga del Norte, with intent to kill and without justifiable cause or sufficient provocation, he wilfully, unlawfully and feloniously attacked one Noel Angcla, inflicting injuries on vital parts which caused death.
The complaint sought damages: (a) Indemnity of victim's death P50,000.00; (b) Loss of earning capacity P20,000.00; total P70,000.00.
Rulie pleaded self-defense at trial.
The Regional Trial Court (Trial Court), Branch 6, Dipolog City, found Rulie guilty beyond reasonable doubt of homicide and imposed an indeterminate sentence of ten (10) years of prision mayor as minimum to fourteen (14) years, eight (8) months and one (1) day of reclusion temporal as maximum, with accessory penalties.
The trial court ordered Rulie to pay Noel's heirs P50,000.00 as civil indemnity and P50,000.00 as moral damages, and costs of suit.

Appeal to the Court of Appeals and Its Ruling

Rulie appealed to the Court of Appeals (CA), docketed CA-G.R. CR No. 01826-MIN; he was granted discretionary bail pending appeal.
By Decision dated December 11, 2020, the CA affirmed Rulie's guilt for homicide but modified damages: ordered payment of (1) civil indemnity Php50,000.00; (2) moral damages Php50,000.00; and (3) temperate damages Php50,000.00, all subject to 6% per annum from finality until full satisfaction.
The CA ordered cancellation of Rulie's cash bond and directed issuance of a warrant of arrest for service of sentence.
The CA's reasoning: it found the element of unlawful aggression absent because, in the CA's view, the imminence of danger had ceased after Noel had punched Rulie while Rulie was carrying a sack of rice; Rulie thereafter allegedly retaliated by striking Noel with excessive force, causing fatal injury.
The CA emphasized comparative characteristics: Noel was about 50 years old, physically impaired/slowed reflexes due to intoxication and lanky build; Rulie was a sober 29-year-old laborer, larger in build; the CA concluded Rulie could have easily subdued Noel, so the means employed were not reasonably commensurate to the alleged attack.

Motion for Reconsideration and Further Procedural Posture

Rulie sought reconsideration of the CA Decision; the CA denied the motion by Resolution dated February 21, 2022.
Rulie then filed the Petition for Review on Certiorari to the Supreme Court, presenting self-defense as his last chance for exoneration.

Issues Presented

Whether Rulie is guilty of homicide despite his plea of self-defense.
Whether the elements of self-defense were present: (1) unlawful aggression on the part of the victim; (2) reasonable necessity of the means employed to prevent or repel such aggression; and (3) lack of sufficient provocation on the part of the person resorting to self-defense.
Whether civil liability arises from the killing if self-defense is established.

Petitioner's Contentions

Rulie maintained he validly defended himself against Noel's unlawful ag