G.R. No. L-6372, March 27, 1911
THE UNITED STATES vs. PASCUAL MOLINA

FACTS

Pascual Molina was convicted of homicide for killing Francisco Gaspar. The prosecution’s eyewitnesses (the wife and daughter of the deceased) testified that Molina, unprovoked, approached Gaspar from behind and attacked him with a bolo. In contrast, Molina testified that he went to Gaspar’s house to settle a family dispute involving their children. Upon arrival, Gaspar greeted him with insults, immediately assaulted him with a bolo, and a struggle ensued. Molina, unarmed, wrestled the bolo away from Gaspar. He claimed that even after being disarmed, Gaspar attempted to seize a hatchet to continue the attack, prompting Molina to strike Gaspar with the bolo, resulting in fatal wounds. Molina’s version was corroborated by his companions. The trial court found that Gaspar was the initial aggressor and that Molina was unarmed but concluded that Molina used excessive force after disarming Gaspar, as he could have fled instead of killing him.

ISSUE

Whether Molina acted in legitimate self-defense, exempting him from criminal liability under the Penal Code.

RULING

Yes. The Supreme Court reversed the conviction and acquitted Molina. The Court accepted the trial court’s finding that Gaspar was the unlawful aggressor and that Molina was unarmed and without provocation. However, it disagreed with the trial court’s conclusion that Molina used excessive force. The evidence showed that the struggle was continuous, and even after being disarmed, Gaspar attempted to seize a hatchet to resume the attack. The danger to Molina’s life persisted throughout the confrontation. Molina had no duty to flee and was entitled to repel the danger by disabling his aggressor. The means employed were rationally necessary to repel the unlawful assault. Therefore, Molina acted in complete self-defense under Article 8(4) of the Penal Code and is exempt from criminal liability.