GR 1412; (April, 1904) (Digest)
G.R. No. 1412 : April 15, 1904
THE UNITED STATES, complainant-appellant, vs. J. C. WINEBRENNER, defendant-appellee.
FACTS:
The defendant, J. C. Winebrenner, confronted Andres Rivera on a Saturday afternoon regarding an incident from the previous Thursday night, wherein Rivera was alleged to have improperly seized a woman in the private part of Winebrenner’s house. Before the confrontation, Winebrenner went to his house to get a sword cane. Upon meeting Rivera, Winebrenner asked about the Thursday night incident. When Rivera denied being present and called Winebrenner a liar, Winebrenner struck Rivera in the face with his fist. Rivera then drew a knife and stabbed Winebrenner in the arm. Winebrenner retaliated with the sword cane, inflicting multiple wounds on Rivera, which required twenty-two days to heal. The trial court held that Winebrenner acted in self-defense and exempted him from criminal liability.
ISSUE:
Whether the defendant, J. C. Winebrenner, is exempt from criminal liability by reason of self-defense.
RULING:
No. The Supreme Court reversed the trial court’s decision and found the defendant guilty. The Court ruled that the requisites for self-defense were not present. Specifically, the Court found that there was sufficient provocation on the part of the accused. Winebrenner provoked the quarrel by approaching Rivera in a hostile manner after arming himself with a sword cane and by striking the first blow immediately after Rivera’s denial. Thus, the illegal aggression originated from Winebrenner, not from Rivera. Consequently, Winebrenner was the offender and not someone acting in lawful defense. No mitigating circumstances were applicable. In accordance with Article 418 of the Penal Code, the Court sentenced J. C. Winebrenner to two months and one day of arresto mayor, and ordered him to pay the doctor’s bills and the costs of the prosecution.
