G.R. No. L-11597; August 1, 1916

FACTS:
In the early morning of April 5, 1915, Dario Padilla left his house to gather bejuco. Upon passing by the house of Severino Mateo, he was invited to go fishing but declined. Shortly after, Padilla remembered he had forgotten a box of matches and returned home. Upon entering, he discovered Severino Mateo holding his wife by the hands with evident lewd intent. Blinded by passion and in defense of his wife’s honor, Padilla struck Mateo with a bolo, inflicting two woundsone serious wound on the left forearm and a lesser wound on the left thumb. The more serious wound took over sixty days to heal and rendered Mateo’s left hand useless.

The prosecution presented a different version. Severino Mateo testified that he, along with three companions, went to Padilla’s house to invite him fishing. Padilla’s wife informed them he was absent. Mateo claimed he entered the house merely to light his cigar from a lamp inside and was attacked by Padilla without provocation as he was leaving.

The defense relied on the testimony of Padilla and his wife, who stated that Mateo had entered the house with illicit intentions. This was corroborated by the finding of Mateo’s hat and a box of matches near the door, undermining his claim that he needed to use the household lamp. The testimony of Mateo’s companions was deemed unreliable as they were at a considerable distance and did not witness the actual encounter inside the house.

ISSUE:
Whether Dario Padilla is criminally liable for the wounds inflicted upon Severino Mateo, or if he acted in lawful defense of his wife’s person and honor, thus exempting him from criminal responsibility.

RULING:
The Supreme Court REVERSED the judgment of the lower court and ABSOLVED Dario Padilla, declaring him exempt from all criminal responsibility.

The Court found that the accused acted in the lawful defense of the person and honor of his wife under Article 8, paragraph 5 of the Penal Code. The evidence established that Severino Mateo entered Padilla’s house at an unseasonable hour under the false pretext of lighting a cigar, despite having matches, and was caught in the act of attempting to abuse Padilla’s wife. The husband, surprised by this aggression, used rational means (his bolo) to repel the attack and prevent the violation. Since neither Padilla nor his wife provoked the incident, his actions were justified as a legitimate exercise of his right to defend his spouse’s honor and person. Consequently, he incurred no criminal liability. Costs were adjudged de oficio.