Case Summary (G.R. No. 7037)
Petitioner and Respondent Roles
The United States prosecuted the defendants for causing serious injuries to Exequiel Castillo. The four defendants appealed their convictions to the appellate tribunal; the appeal was brought by the defendants.
Key Dates and Locale
Material events occurred on the nights of December 26 and December 28, 1909, in the pueblo of Tanauan, Province of Batangas, at and near the parochial building (upper hall and ground floor). (Decision and procedural dates appear in the record but are not set out here.)
Applicable Law
The case was decided under the Penal Code provisions cited in the record, specifically article 8 (paragraphs 4 and 5) concerning lawful defense and defense of others, and under the provisional law for the application of the Penal Code (rule 51), as those statutes and rules were applied by the courts below and by the appellate tribunal.
Procedural Posture
A judgment of conviction (by the trial judge) against the four named defendants was appealed by them. The appellate tribunal reviewed the factual record, witness testimony, medical evidence, and legal arguments; it analyzed who provoked the affray and whether the defendants’ acts were privileged under statutory provisions on lawful defense and defense of relatives.
Factual Background — Initial Incident (Dec. 26)
On December 26, 1909, Jose Laurel allegedly kissed Concepcion Lat in the street while she was accompanied by several young people including Exequiel Castillo. Laurel then ran toward his house, pursued unsuccessfully by the girl’s companions and by Castillo.
Factual Background — The Parochial Building Encounter (Dec. 28)
On December 28, 1909, both Castillo and Laurel attended an entertainment in the upper floor of the parochial building. Castillo was informed—according to some testimony—by intermediaries that Laurel wished to speak with him. A meeting occurred near the ground-floor door. A quarrel ensued, and as a result Castillo received multiple and severe injuries. Laurel also suffered two slight head wounds.
Medical Evidence of Castillo’s Injuries
Dr. Sixto Rojas testified to multiple, serious injuries to Castillo: a 3–4 cm penetrating wound in the left chest entering the lung (with hemoptysis), a 10–11 cm wound on the back of the left arm severing the ulnar nerve and damaging vessels and bone, contusion of the right temple with significant ecchymosis, and a contusion of the abdomen with consequence to nearby viscera. The physician described prolonged treatment and partial permanent impairment (notably of the left hand’s little and ring fingers).
Key Factual Conflicts
The record contains stark contradictions as to who invited whom to the ground floor and who struck first. Castillo and his witnesses testified that Laurel summoned or awaited Castillo and then suddenly stabbed Castillo with a knife. Laurel and his witnesses testified that Castillo, after being summoned, struck Laurel twice with a cane, whereupon Laurel drew a pocketknife in self-defense. Witness accounts vary on the sequence of events, who carried weapons, and who first assaulted the other.
Witnesses and Corroboration
Prosecution witnesses (including Castillo, Roque Castillo, Primitivo Gonzalez) described Castillo as having waited on the ground floor for Laurel and being suddenly stabbed by Laurel. Police testimony (Lucio Villa) recorded that Lucio found Laurel walking away with a bloody pocketknife. Defense witnesses (Laurel, Baltazara Rocamora, Benito Valencia, Domingo Panganiban, Conrado Laurel) testified that Laurel had to be called repeatedly before descending, that Castillo struck Laurel first with a cane, and that Laurel used a pocketknife only in defense. Some witnesses corroborated that Laurel bore recent head contusions.
Court’s Assessment of Who Initiated the Encounter
The appellate tribunal, after evaluating timing, witness credibility, and circumstantial logic, concluded it was more probable that Castillo—being the aggrieved suitor of Concepcion Lat—was the party who instigated the meeting and awaited Laurel on the ground floor. The court reasoned that (1) Castillo went down first and waited nearly half an hour for Laurel; (2) Laurel was called repeatedly and was reluctant to descend, which is inconsistent with the theory that Laurel had summoned Castillo; and (3) given the context (the earlier kiss and Castillo’s interest in the girl), it was more plausible that Castillo sought explanations and provoked the interview.
Court’s Conclusion on Who Struck First
After weighing contradictory testimony, the court found by force of probability that Castillo first assaulted Laurel by striking him twice with a cane. The court considered it unlikely that Castillo, after receiving a dangerous chest wound penetrating the lung, could have struck two successive blows and pursued Laurel. On that basis the court concluded that Laurel’s use of a pocketknife occurred in immediate defense of himself.
Application of Article 8, Penal Code — Self-Defense (Paragraph 4)
The court applied paragraph 4 of article 8 (the statutory provision on lawful defense). It found the three requisites of lawful self-defense present as to Jose Laurel: (1) there was unlawful aggression by Castillo; (2) Laurel lacked sufficient provocation to have instigated the conflict; and (3) the means employed by Laurel (use of a pocketknife) were proportionate and reasonably necessary to repel the aggression (Castillo had struck Laurel with a cane and pursued him). On that basis the court held Jose Laurel exempt from criminal responsibility.
Application of Article 8, Penal Code — Defense of Relatives (Paragra
...continue readingCase Syllabus (G.R. No. 7037)
Case Citation, Court and Decision
- Reported at 22 Phil. 252; G.R. No. 7037; decision rendered March 15, 1912.
- Decision authored by Justice Torres.
- Appeal from a judgment of conviction rendered by the Honorable Mariano Cui (judgment found on page 117 of the record).
- Justices Johnson, Carson, Moreland, and Trent concurred in the opinion.
Parties and Counsel (as presented in the record)
- Plaintiff and appellee: The United States.
- Defendants and appellants: Jose Laurel, Conrado Laurel, Vicente Garcia, Domingo Panganiban (four named defendants on appeal), and others named in trial but the appeal arises from the four above-named defendants.
- The record reflects that well-written briefs were filed in the trial court by both prosecution and defense.
Chronology and Locale of Relevant Events
- December 26, 1909: Night when Jose Laurel allegedly kissed Concepcion Lat in the street of the pueblo of Tanauan, Batangas; the act was witnessed by Concepcion Lat’s escort, Exequiel Castillo, and others.
- December 28, 1909: Night of the altercation at the parochial building (upper story entertainment and subsequent meeting on the ground floor/yard) where Exequiel Castillo was seriously wounded and Jose Laurel received head wounds.
- Following day(s): Medical attention and observations by Dr. Sixto Rojas; arrests and police activity documented the next morning.
- Appeal decided March 15, 1912.
Background Facts (events preceding the affray)
- On December 26, 1909, while Concepcion Lat walked home from Exequiel Castillo’s house accompanied by several young people, Jose Laurel allegedly approached and suddenly kissed her, then fled toward his house pursued unsuccessfully by the girl’s companions, including Exequiel Castillo.
- Two nights later, during an entertainment at the parochial building in Tanauan, an encounter occurred on the ground floor (or yard) between Exequiel Castillo and Jose Laurel after one or both were summoned to speak about the earlier kissing incident.
Overview of the Dec. 28 Encounter (as recounted in the record)
- Exequiel Castillo and Jose Laurel were both at the entertainment in the parochial building’s upper floor; an exchange of messages and an eventual meeting downstairs resulted in a private discussion that escalated into a violent quarrel.
- Accounts diverge sharply as to who invited whom, who provoked the altercation, and who struck the first blow.
- The altercation resulted in Exequiel Castillo being seriously wounded and Jose Laurel suffering two slight wounds to the head.
- Police intervened; Lucio Villa, a policeman, arrested Jose Laurel at the scene carrying a bloody pocketknife.
Medical Evidence — Dr. Sixto Rojas’s Examination and Findings
- Dr. Sixto Rojas began treatment early the morning following the affray and attended Castillo for fourteen consecutive days.
- Wounds and physical findings on Exequiel Castillo:
- A wound on the left side of the chest at the level of the fourth rib, 3 to 4 centimeters in depth, penetrating into the lung.
- A wound on the back of the left arm and in the conduit for the ulnar nerve, 10 to 11 centimeters in length, penetrating to the bone and injuring nerves and arteries; the ulnar nerve was severed.
- A contusion on the right temple with ecchymosis and hemorrhage of the eye tissues.
- A contusion in the back of the abdomen near the left cavity, causing reactive injury involving the stomach and the right cavity.
- Clinical course and prognosis:
- The chest wound penetrated the lung, caused hemoptysis (patient spat blood), and there must have been pulmonary hemorrhage; timely medical aid prevented death.
- The ulnar nerve injury produced permanent uselessness of the little and ring fingers of the left hand.
- Abdominal contusion improved in four to five days; temple contusion took ten to twelve days to heal though ecchymosis might persist about three months.
- Stitches in the left arm were removed after twelve days; further healing required additional time though the internal chest wound was healing by the time the physician ceased attending.
- The physician’s opinion emphasized the seriousness of the chest and left-arm wounds and the risk to life had prompt medical care not been given.
Trial Evidence — Prosecution Witnesses (summarized)
- Exequiel Castillo (victim) testified:
- He was summoned downstairs from the upper hall; upon meeting Laurel and answering a question about letters, Laurel suddenly stabbed him in the left breast with a knife.
- Castillo struck Laurel with a cane; Laurel then received a knife thrust in Castillo’s arm; Castillo was again struck on left side with a fist and on the right temple with a cane.
- Castillo stated he had been courting Concepcion Lat for a month and had grievance over Laurel’s kiss on Dec. 26.
- Roque Castillo (brother of Exequiel) testified:
- At Domingo Panganiban’s request he suggested Exequiel go downstairs to meet Laurel.
- Observed Laurel and others come downstairs; noticed a bulge on Conrado Laurel’s waist and took Laurel’s revolver (without cartridges) and later delivered it to his father.
- Heard a commotion and found Exequiel wounded in the drug store; corroborated delivery of the revolver to Sixto Castillo.
- Primitivo Gonzalez (relative and companion of Exequiel) testified:
- Confirmed that Exequiel went downstairs after a summon; observed Laurel strike Exequiel with a handkerchief and that Exequiel hit Laurel with a cane.
- Testified that Vicente Garcia stabbed Exequiel in the back, Conrado Laurel struck him on head with a cane, and policemen intervened.
- Lucio Villa (policeman) testified:
- Arrested Jose Laurel leaving the scene, walking at ordinary gait and carrying a bloody pocketknife, which witness took from him.
Trial Evidence — Defense Witnesses and Defendants’ Testimony (summarized)
- Jose Laurel (defendant) testified:
- He was summoned three times (by Domingo Panganiban, Alfredo Yatco, Felipe Almeda) before going downstairs.
- On being asked why he kissed Concepcion Lat, he answered that she was fickle and prodigal of "yes"; Exequiel struck him twice on the head with a cane or club, knocking him down.
- Laurel stated he took his pocketknife in self-defense and