G.R. No. 44023 ; October 26, 1935
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. DOMINGO ABILES, defendant-appellant.

FACTS

On the night of May 11, 1935, a quarrel arose between Domingo Abiles and Maximo Rodas in a billiard saloon in Iloilo. The saloon owner asked both to leave. Rodas left first, and Abiles followed five minutes later. Shortly after, a fight ensued outside. The saloon owner saw them in a hand-to-hand struggle, with Abiles bleeding and about to fall. Rodas was later found with multiple serious wounds and died. Abiles surrendered to a policeman, claiming self-defense. He testified that after leaving, Rodas attacked him without warning, stoned him, threw him to the ground, knelt on his chest, and choked him. In that position, Abiles used his knife to stab Rodas until he could break free. Two eyewitnesses corroborated his account. The prosecution presented no witnesses to the start of the fight. Evidence showed Rodas was bigger, sturdier, feared in the community, and had a prior conviction for physical injuries.

ISSUE

Whether the appellant, Domingo Abiles, acted in lawful self-defense, justifying his acquittal for the homicide of Maximo Rodas.

RULING

Yes. The Supreme Court reversed the trial court’s judgment and acquitted Domingo Abiles. The Court found his testimony credible and corroborated, establishing that he acted in self-defense. The circumstances—including Rodas waiting outside, the sudden attack, and Abiles being overpowered and choked while on the ground—showed that Abiles had reasonable grounds to believe his life was in danger. His use of the knife to free himself from the attack was a justified and necessary act of self-preservation. Therefore, he incurred no criminal liability.

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