Case Summary (G.R. No. 240316)
Facts and Charges
Natividad Luague and Wenceslao Alcansare, spouses residing in Lupuhan, Calatrava, Occidental Negros, were charged with homicide following the fatal stabbing of Paulino Disuasido. On the day of the incident, Paulino approached Natividad at her home and made uninvited amorous advances which escalated into a threat involving a knife. Natividad defended herself by seizing Paulino’s knife and stabbing him in the abdomen, causing fatal injuries. Wenceslao was not present at the time, as he had gone to grind corn elsewhere. Both spouses were sentenced to terms of prision mayor and reclusion temporal, with an indemnity awarded to the heirs of the deceased. The accused appealed for a review and acquittal.
Circumstances Surrounding the Incident
Natividad was alone with her three young children when Paulino entered her home and attempted to coerce her into submission despite her refusal. When Paulino threatened her with a knife and pursued her attempts to avert his advances, Natividad took advantage of the moment when Paulino left the knife unattended to defend herself by stabbing him. Afterward, she surrendered herself to the authorities. The spouses’ conviction was based on the alleged theory of a conspiracy to kill Paulino out of jealousy by Wenceslao, carried out by Natividad.
Legal Analysis: Legitimate Self-Defense Protecting Honor
The Court emphasized that Natividad’s actions fall within the exemption of criminal liability under Article 11, subsection 1, of the Revised Penal Code, which recognizes legitimate self-defense. The Court underscored that a woman’s honor holds significant value — arguably equal to or surpassing that of her life — and that an attack on her chastity constitutes an aggression justifying defensive force, including lethal means if necessary. This interpretation is reinforced by authoritative commentaries and by jurisprudence from the Supreme Court of Spain, which recognized protection of a woman’s honor against imminent sexual violation as grounds for legitimate defense exempting criminal responsibility.
Rejection of Prosecution’s Conspiracy Theory
The prosecution’s claim that Wenceslao, motivated by jealousy, conspired to kill Paulino—with his wife acting on his behalf—was found unsubstantiated and lacking in probability. Witness testimonies failed to convincingly prove the accused couple’s plan or coordinated action. The absence of preparations or weapons supporting the theory of a deliberate conspiracy further undermined the prosecution's case. Furthermore, the conduct of witnesses supporting the prosecution’s version was inconsistent and unreliable, with contradictions and implausible behavior noted, such as the failure to seek timely help or accurately identify perpetrators.
Evaluation of Evidence
Key prosecution witnesses provided contradictory and weak testimony, which the trial court erroneously credited. Testimonies lacked corroboration and logical consistency, failing to establish Wenceslao’s participation or even a solid motive for joint action. The supposed evidence that Paulino was stabbe
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Background and Procedural History
- The spouses, Natividad Luague and Wenceslao Alcansare, were charged and convicted by the Court of First Instance of Occidental Negros for homicide.
- Wenceslao Alcansare was sentenced to a minimum of eight years and one day of prision mayor and a maximum of fourteen years, eight months, and one day of reclusion temporal.
- Natividad Luague was sentenced to a minimum of six years and one day of prision mayor and a maximum of twelve years and one day of reclusion temporal.
- Both defendants were ordered to jointly and severally indemnify the heirs of the deceased, Paulino Disuasido, in the sum of one thousand pesos, including court costs.
- The defendants appealed, praying for reversal of the conviction and for acquittal.
Facts of the Case
- On the morning of February 18, 1935, Natividad Luague was alone in her house with only her three young children; her husband Wenceslao was away grinding corn several kilometers away.
- Paulino Disuasido arrived at her house and began making advances to her.
- Despite her repeated refusals, Paulino insisted and followed her to the kitchen with a knife, threatening her with death.
- As Paulino embraced her and tried to physically violate her, he left the knife on the floor.
- Taking advantage of his momentary distraction, Natividad picked up the knife and stabbed him in the abdomen.
- Paulino fled through a window, sustaining injuries from the fall onto rocks.
- Immediately after, Natividad went to the poblacion to surrender to authorities and report the incident.
Legal Issue: Legitimate Self-Defense and Exempting Circumstance
- The act of Natividad Luague in mortally wounding Paulino Disuasido constitutes an exempting circumstance under Article 11, subsection 1, of the Revised Penal Code.
- Legitimate defense includes protection not only of life but also of property and above all, honor.
- Commentators emphasize the special value of a woman’s honor, considering the irreversible harm caused by sexual assault or attempted rape.
- The Supreme Court noted that an attempt to rape justifies legitimate self-defense, as the assault places the victim in imminent danger of an irreparable violation.
- The Court of Spain's precedent was cited to affirm that a woman’s defense of her honor against threatened violation invol