G.R. No. 32948 , November 1, 1930
PEOPLE OF THE PHILIPPINE ISLANDS vs. SANTOS QUINTO

FACTS

On December 26, 1929, in Tiaong, Tayabas, Santos Quinto shot Bartolome Perez twice with a revolver and then stabbed him twice with a bolo, causing his instant death. Quinto was charged with murder, but the trial court convicted him of homicide, finding no qualifying circumstances proven. He was sentenced to 14 years, 8 months, and 1 day of reclusion temporal, with indemnity and costs. Quinto appealed, claiming self-defense and arguing that the trial court erred in not appreciating mitigating circumstances.

ISSUE

Whether the accused, Santos Quinto, acted in self-defense, and if not, whether mitigating circumstances should be applied to reduce his penalty.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the trial court’s judgment. The Court held that:
1. Self-defense was not established. Quinto’s claim that he was attacked by Perez and Valentin Padilla was contradicted by prosecution witnesses, who testified that Quinto initiated the assault without provocation. The physical evidence and witness accounts did not support a finding of unlawful aggression on the part of the deceased.
2. No mitigating circumstances were applicable. The Court found no evidence of unlawful attack, lack of provocation, or lack of intent to inflict serious injury. Quinto’s actionsfiring two shots and then delivering fatal bolo woundsdemonstrated a determined effort to kill, negating any claim of mitigated intent.
3. The penalty imposed was correct. The trial court properly convicted Quinto of homicide, as the evidence did not establish treachery, premeditation, or cruelty. The penalty of reclusion temporal in its medium period, plus indemnity, was in accordance with the law.

DISSENTING OPINION:
Justices Malcolm, Johns, and Romualdez dissented, arguing that the evidence suggested the aggression came from the deceased and Valentin Padilla. They believed Quinto’s plea for “patience” indicated he was not the aggressor and that incomplete self-defense should apply, warranting a penalty one degree lower. However, the majority found the prosecution’s evidence more credible.