G.R. No. 1627 : April 2, 1904
THE UNITED STATES, complainant-appellee, vs. GEORGE WASHINGTON, defendant-appellant.

FACTS:
The defendant, George Washington, was a prisoner serving a three-year sentence at Bilibid Prison. On April 29, 1903, he was assigned to oversee a cement bed and was instructed by the master mechanic not to allow anyone to take cement without proper authorization. During his temporary absence, another prisoner, H. S. Harris, attempted to take cement without authorization. Upon returning, Washington confronted Harris, leading to a verbal altercation. Harris struck the first blow and attempted to grab a shovel. In response, Washington picked up a bamboo stick (described as thick as a wrist) and struck Harris across the back. The fight was eventually stopped, and Harris was hospitalized for about a month. Washington was placed in disciplinary confinement. He was subsequently convicted in the Court of First Instance of assault with a deadly weapon causing injuries resulting in disability for more than thirty days and sentenced to one year imprisonment.

ISSUE:
Whether the defendant, George Washington, should be held criminally liable for assault with a deadly weapon under the circumstances.

RULING:
The Supreme Court reversed the conviction and acquitted the defendant. The Court found that Harris was the aggressor: he provoked the incident by unlawfully taking cement, struck the first blow, and attempted to escalate the violence by reaching for a shovel. Washington’s use of the bamboo stick was in response to this aggression. The injuries, while resulting in a month-long hospitalization, were not deemed serious under the circumstances. Additionally, Washington had already been punished through prison disciplinary measures (confinement in a dark cell), and he was shown to be a well-behaved prisoner with a good record. Considering these factors, the Court held that criminal liability was not warranted.