G.R. No. 31479 , November 29, 1929
PEOPLE OF THE PHILIPPINE ISLANDS vs. EDUARDO TOLENTINO

FACTS

The defendant, Eduardo Tolentino, was charged with murder for killing Espiridion Candelaria on November 1, 1928, in Los Baños, Laguna. Tolentino admitted to inflicting the fatal wound but claimed he acted in self-defense. According to him, during an argument, Candelaria threw a book at him, then brandished a knife and threatened to stab him. Tolentino retreated, grabbed his bolo, and attempted to disable Candelaria’s knife-wielding hand, but instead struck Candelaria on the head. He then fled and surrendered to authorities over a month later. The prosecution presented evidence, including the testimony of Dr. Sixto A. Francisco, who described the fatal wound as a large, clean cut on the back of Candelaria’s head, consistent with being struck from behind or while in a reclining position. No weapon was found near Candelaria’s body. Tolentino also showed a scar on his forearm, which he claimed was inflicted by Candelaria, but the trial court doubted this claim.

ISSUE

Whether the defendant acted in self-defense, thereby exempting him from criminal liability.

RULING

No. The Supreme Court rejected the plea of self-defense. The physical evidence contradicted Tolentino’s account: (1) no weapon was found in the room to support his claim that Candelaria attacked him with a knife, and (2) the nature, location, and extent of the fatal wound indicated that Candelaria was either struck from behind or while his body was in a reclining position, which was inconsistent with a defensive strike aimed at disabling a hand. However, considering evidence that the deceased was quarrelsome and the defendant was generally peaceable, the Court recognized the presence of a mitigating circumstance. Accordingly, the penalty was reduced from fourteen years, eight months, and one day of reclusion temporal to twelve years and one day of reclusion temporal, with the rest of the trial court’s judgment affirmed.