G.R. No. 1522 : February 11, 1904
THE UNITED STATES, complainant-appellee, vs. POLICARPO IDICA, defendant-appellant.

FACTS:
On the afternoon of July 14, 1903, in Sinait, Ilocos Sur, Policarpo Idica and Placido Abella, along with others, were walking and talking near Tagibay. Idica, who was walking ahead, suddenly turned and struck Abella, who was walking behind him, with a bolo, inflicting two mortal wounds. Abella died shortly thereafter. Eyewitnesses testified that there was no immediate quarrel preceding the attack, though there had been prior discussions about a land dispute between the parties that had been ongoing for years. The witnesses found Abella’s bolo still sheathed at his side. Idica pleaded not guilty, claiming self-defense. He testified that Abella had become enraged during a boundary dispute and attempted to strike him first, and he merely warded off the blow, resulting in Abella’s death. This claim was contradicted by the eyewitness accounts.

ISSUE:
Whether the crime committed by the accused is murder or simple homicide.

RULING:
The Supreme Court ruled that the crime committed is simple homicide, not murder. The qualifying circumstances of evident premeditation and alevosia (treachery) were not proven. There was no evidence that Idica had preconceived and reflected upon the criminal design beforehand; the longstanding land dispute alone was insufficient to establish evident premeditation. Furthermore, the attack was made face-to-face and openly, not in a manner that specially and directly insured its execution without risk to the assailant. The claim of self-defense was rejected as unsupported by evidence and contradicted by witnesses who stated Idica was the unprovoked aggressor and that the victim’s bolo was found sheathed. No aggravating or mitigating circumstances attended the commission of the crime. The decision of the lower court was affirmed, with the imposition of the corresponding penalty for homicide and its accessory penalties.