Case Summary (G.R. No. 951)
Facts of the Case
On the day of the incident, while Juan Salandanan was away from his home, Domingo Alba Clemente entered and made an advance toward Salandanan's wife, attempting to engage her in illicit intercourse. When she resisted, Alba escalated his actions to an attempted rape. In her moment of distress, she screamed for help, prompting Salandanan's return. Upon his arrival, Salandanan encountered Alba, who had already inflicted injuries on his wife and proceeded to attack Salandanan himself, resulting in a violent struggle. During this confrontation, Salandanan managed to seize Alba's weapon, a bolo, and inflicted a fatal wound on Alba before he succumbed to his injuries shortly thereafter.
Initial Ruling by Lower Court
The lower court found Salandanan guilty of homicide, applying the mitigating circumstances of immediate provocation and sufficient excitement to overcome self-control. He was sentenced to a term of six years and one day of prision mayor. The court reasoned that although self-defense was acknowledged, Salandanan's act of using the weapon after disarming Alba was deemed unjustified because the necessity of the means employed had not been sufficiently proven.
Analysis of Self-Defense
The higher court disagreed with the lower court's assessment, emphasizing that Salandanan faced imminent and unlawful aggression from Alba, who had already harmed both Salandanan and his wife. The court maintained that the ongoing struggle constituted an immediate threat to Salandanan’s life, particularly after he had sustained a serious wound to his breast. The court highlighted that the mere act of disarming Alba does not negate the potential danger, as the struggle could have turned unfavorable at any moment. Salandanan's reaction was framed as a reasonable response under extraordinary circumstances, justifying his
...continue readingCase Syllabus (G.R. No. 951)
Case Citation
- Jurisprudence: 1 Phil. 478
- G.R. No. 951
- Date of Decision: November 13, 1902
Parties Involved
- Complainant/Appellee: The United States
- Defendant/Appellant: Juan Salandanan
Facts of the Case
- The incident occurred one afternoon while Juan Salandanan was away from his home.
- Domingo Alba Clemente entered Salandanan's house and made an illicit proposal to Salandanan's wife.
- When the wife refused his advances, Alba attempted to rape her.
- In the course of the attack, Alba injured her with a bolo (a type of machete).
- Juan Salandanan returned home upon hearing his wife's screams for help.
- Upon seeing Salandanan, Alba turned his aggression towards him and inflicted a serious wound to Salandanan's breast.
- A violent struggle ensued between Salandanan and Alba.
- During the struggle, Salandanan managed to seize the bolo from Alba and subsequently inflicted a fatal wound on him, leading to Alba's death shortly after.
Trial Court Proceedings
- The lower court found Juan Salandanan guilty of homicide.
- Mitigating circumstances considered included immediate provocation and excitement that impaired Salandanan's sel