Case Summary (G.R. No. L-32104)
Admission of Homicide and Claim of Self-Defense
Bauden admitted to killing Piso but claimed that he acted in self-defense. He testified that he encountered Piso gathering corn from his field, escalating into a confrontation where Piso threatened him and pursued him to his home. Upon confronting him armed with a bolo, Bauden asserts that he acted to protect himself.
Evaluation of Credibility and Evidence
The court raised doubts about Bauden's claim of self-defense. It noted that if legitimate aggression was occurring, Bauden would have utilized the safety of his home rather than confront Piso outside. The absence of evidence supporting Bauden's assertions—particularly regarding the sequence of aggression and the nature of their altercation—further underpinned the court's skepticism.
Self-Defense Criteria and Rulings
According to established jurisprudence, a claim of self-defense necessitates clear and convincing evidence. The burden rested on Bauden to prove that his actions were a response to an immediate and unlawful aggression. The court found his defense insufficient, pointing out inconsistencies in his statements and suggesting he was not adequately threatened to warrant the use of lethal force.
Physical Evidence and Testimony Analysis
Witness testimonies pointed to Piso’s threatening behavior; however, the injuries Bauden inflicted on Piso did not align with his narrative. The court observed that Bauden's counterattacks occurred while Piso was armed and posed a threat, raising questions as to why Bauden engaged outside the safety of his home with a less lethal weapon.
Conclusion of th
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Case Overview
- The case revolves around the appeal of Restituto Bauden, who was convicted of homicide for the death of Alejandro Piso on August 2, 1945, in Manapla, Negros Occidental.
- The accused admitted to killing Piso but claimed it was in self-defense.
Facts of the Case
- On the day of the incident, Bauden found Piso gathering corn from his field. A confrontation ensued, leading to Piso threatening Bauden.
- Piso allegedly pursued Bauden, throwing stones and making threats against his life.
- After fleeing to his home, Piso continued to threaten Bauden, ultimately returning armed with a bolo and cutting down two banana trees on Bauden’s property.
- As Piso approached Bauden’s house with the intent to attack, Bauden armed himself with a piece of wood and confronted Piso, leading to a physical struggle in which Bauden fatally wounded Piso.
Legal Arguments
Defense Claims:
- Bauden contended that he acted in legitimate self-defense as he faced unlawful aggression from Piso, who was armed with a bolo.
- He argued that he had the right to defend himself against the threat posed by Piso, who had previously threatened to kill him.
Prosecution Claims:
- The prosecution argued that Bauden's actions were not in self-defense, citing inconsistencies in his statements and the manner in w