GR 224102; (July, 2017) (Digest)
G.R. No. 224102. July 26, 2017.
RYAN MARIANO Y GARCIA, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.
FACTS
Petitioner Ryan Mariano was convicted of Frustrated Homicide for stabbing Frederick Natividad. The prosecution alleged that Mariano, without provocation, stabbed Natividad twice after Natividad went to a house to report being punched by Yuki Rivera. The defense presented a different narrative. Mariano claimed he acted in defense of relatives. He testified that Natividad, who was drunk and belligerent, had slapped Yuki, kicked a minor named Pia, and then punched Mariano’s common-law wife, Pamela. When Mariano intervened and pushed Natividad, Natividad stood up, armed himself with a piece of wood, and repeatedly attempted to hit Mariano. It was only then, while evading these blows, that Mariano picked up a knife and stabbed Natividad.
ISSUE
Whether the Court of Appeals erred in affirming Mariano’s conviction by failing to appreciate the justifying circumstance of defense of a relative or stranger.
RULING
The Supreme Court REVERSED the conviction and ACQUITTED Mariano. The Court emphasized that in evaluating claims of self-defense or defense of others, the state of mind of the accused at the precise moment of the incident is paramount. The legal test is whether the means employed were reasonably necessary to repel the aggression, judged from the perspective of a person similarly situated and not with the benefit of hindsight. The Court found that all requisite elements for defense of a stranger under Article 11(3) of the Revised Penal Code were present. Natividad was the unlawful aggressor, as established by his violent attacks on three persons, including minors. His aggression was ongoing and continuous when Mariano acted. Although Natividad’s drunken state may have made his blows less accurate, the imminent danger to Mariano and his family was real. The means employed were reasonably necessary given the incessant nature of the attack with a weapon, and there was no evidence Mariano was motivated by revenge or evil motive. The lower courts erred in discounting the defense by imposing an unrealistic standard of conduct detached from the sudden peril Mariano faced. His actions were a justified response to the unlawful aggression.