G.R. No. 1479 : April 16, 1904
THE UNITED STATES, complainant-appellee, vs. VICTORINA DE LOS SANTOS, defendant-appellant.

FACTS:
The accused, Victorina de los Santos, was tried in the Court of First Instance of Bulacan for the crime of assault (lesiones). The evidence established that the accused and her brothers were co-owners of a lot in Malolos. A dispute arose when the accused began constructing a house on the lot and her brother, Valentin de los Santos, asked her to suspend the work until their elder brother arrived. During the quarrel, the accused struck her brother with a bolo, inflicting a serious wound on his right wrist. The accused testified that her brother attempted to strike her with a stick, but her own witness only testified to hearing threatening words, not an actual physical assault. The trial court convicted her of assault and sentenced her to one year, eight months, and one day of imprisonment.

ISSUE:
Whether the accused acted in lawful self-defense, thereby exempting her from criminal liability.

RULING:
No. The Supreme Court affirmed the judgment of conviction. The defense of self-defense was not sufficiently established. The accused’s sole witness failed to corroborate her claim that her brother had physically attacked her with a stick; the witness only testified to verbal threats. Consequently, the essential element of unlawful aggression required to justify self-defense was absent. The trial court’s decision was found to be in accordance with the law. The appealed judgment was affirmed, with costs against the appellant.