G.R. No. 43469; August 21, 1935
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. BEATRIZ YUMAN, defendant-appellant.

FACTS

Beatriz Yuman and Marciano Martin lived together without being married for three to four years. On March 5, 1935, after Martin had left their dwelling, Yuman found him at a cockpit. They traveled together in a vehicle, where Martin expressed his intent to end their relationship. Upon alighting at a street corner, an argument ensued. Martin was rude and hostile, warning Yuman not to meddle in his affairs. Yuman then stabbed Martin in the right lumbar region with a penknife, injuring his kidney. Martin fled and sought help from a policeman, who arrested Yuman. The following day, Martin died from the wound. Yuman was convicted of homicide by the trial court.

ISSUE

Whether the trial court erred in not appreciating the elements of legitimate self-defense or, alternatively, certain mitigating circumstances in favor of the accused.

RULING

The Supreme Court affirmed the conviction but modified the penalty. Legitimate self-defense was not applicable because there was no unlawful aggression on the part of the deceased. A mere push or hostile words did not constitute unlawful aggression justifying the use of a lethal weapon. The Court, however, found the presence of two mitigating circumstances: (1) obfuscation due to the emotional distress from the sudden breakup after years of cohabitation and the harsh treatment received, and (2) lack of instruction of the accused. The aggravating circumstance of evident premeditation was not proven. With two mitigating circumstances and no aggravating circumstance, the indeterminate penalty was reduced to four years of prision correccional as minimum to eight years and one day of prision mayor as maximum.

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