G.R. No. 4685
THE UNITED STATES, plaintiff-appellee, vs. ENG-JUA, ET AL., defendants-appellants.
September 17, 1908

FACTS:
The defendants-appellants, Eng-Jua, et al., were charged with a crime and found guilty by the trial court for inflicting wounds upon a complaining witness. On appeal, counsel for the appellants contended that they were entitled to exemption from criminal liability under section 6 of article 8 of the Penal Code, which provides for the defense of a stranger. They argued that they acted in defense of one Sygaga, who they claimed was attacked and violently maltreated by the complaining witness.

ISSUE:
Whether the appellants are exempt from criminal liability under the defense of a stranger, as the alleged dispute involving Sygaga had already terminated before their intervention.

RULING:
No. The Supreme Court affirmed the judgment and sentence of the trial court. The Court found that the evidence clearly showed that the dispute between Sygaga and the complaining witness had already concluded before the appellants arrived on the scene. Their subsequent attack on the complaining witness was not made to protect Sygaga, who was no longer in danger of assault. Instead, the Court determined that the appellants’ actions were actuated by revenge and resentment for what they considered the ill-treatment and abuse of their friend Sygaga, rather than a genuine desire to prevent or repel an ongoing assault upon him. Therefore, the essential circumstances for the exemption of defense of a strangernamely, illegal aggression, reasonable necessity of the means employed, and the absence of revenge, resentment, or other illegal motivewere not present.