GR 214883; (September, 2015) (Digest)
G.R. No. 214883 , September 02, 2015
People of the Philippines, Plaintiff-Appellee, vs. Cristina Samson, Accused-Appellant.
FACTS
Accused-appellant Cristina Samson was charged with Parricide for stabbing her husband, Gerry Delmar, on June 27, 2002. Upon arraignment, she pleaded not guilty and invoked self-defense, leading to a reverse trial. The defense version states that on the said date, Gerry arrived home drunk, scolded and slapped Cristina for not having cooked food. After being pacified by her father, Gerry returned, pointed a knife at Cristina’s neck, slapped her twice, and threatened her. Cristina pushed Gerry, causing him to fall, and she took the knife. While holding the knife pointed at Gerry near her chest, he suddenly grabbed her, causing the knife to contact his chest. The prosecution’s version, primarily from the testimony of their daughter Christine, stated that during the fight, Cristina got a knife from the roof and stabbed Gerry. The Regional Trial Court (RTC) convicted Cristina of parricide, sentencing her to reclusion perpetua and ordering her to pay damages. The Court of Appeals (CA) affirmed the RTC decision, finding her claim of self-defense untenable as the unlawful aggression had ceased when she disarmed Gerry.
ISSUE
Whether or not the Court of Appeals erred in not appreciating the justifying circumstance of self-defense in favor of accused-appellant Cristina Samson.
RULING
The Supreme Court GRANTED the appeal, REVERSED and SET ASIDE the CA decision, and ACQUITTED Cristina Samson. The Court held that all requisites of self-defense under Article 11 of the Revised Penal Code were present. First, unlawful aggression persisted even after Cristina disarmed Gerry, as he immediately stood up and grabbed her, creating a continuous real and imminent threat to her life. Second, the means employed were reasonably necessary; using the knife already in her hand to repel Gerry’s sudden advance was proportionate to the aggression. Third, there was lack of sufficient provocation; Cristina’s act of pushing Gerry was a natural reaction to his initial armed aggression and did not constitute provocation. The Court also found her flight acceptable due to fear of retaliation from Gerry’s siblings, not from the law, and resolved any lingering doubts in her favor. Consequently, she was justified in killing her husband and incurred no civil liability.