G.R. No. 38486; October 21, 1933
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. JUAN DIMAYUGA, defendant-appellant.

FACTS

The appellant, Juan Dimayuga, was the secretary to his brother, a legislative representative. The victim, Enrique K. Laygo, was an employee of the National Library and a contributor to El Debate. On July 28, 1932, an article written by Laygo in El Debate contained a mild slur against Dimayuga’s brother. That same day, Dimayuga, angered by the article, sought out Laygo at his office but failed to find him. Later, both men arrived at the residence of Valeriano Luz on Lardizabal Street, Manila, where Dimayuga was lodging. Upon entering the house, Dimayuga retrieved a revolver from his bedroom. Shortly after, shots were fired, and Laygo was found dead on the floor with two fatal gunshot wounds. Dimayuga claimed self-defense, alleging that Laygo had attacked him with a knife. The trial court convicted Dimayuga of homicide.

ISSUE

Whether the trial court correctly convicted Juan Dimayuga of homicide, rejecting his claim of self-defense.

RULING

Yes, the conviction is affirmed but the penalty is modified. The Supreme Court found the claim of self-defense untenable. The physical evidence, including the trajectory of the bullets and the relaxed state of the victim’s hands, contradicted Dimayuga’s story of a violent knife attack. The Court found motive in Dimayuga’s political animosity and anger over the published article. The judgment of the Court of First Instance finding Dimayuga guilty of homicide was affirmed, but pursuant to Act No. 4103 (the Indeterminate Sentence Law), the penalty was modified to an indeterminate sentence ranging from eight years and one day of prision mayor to fourteen years, eight months and one day of reclusion temporal.

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