G.R. No. L-12963, October 25, 1917
THE UNITED STATES, plaintiff-appellee, vs. URBANO DOMEN, defendant-appellant.

FACTS:
The defendant, Urbano Domen, admitted to inflicting a fatal wound on the right arm of Victoriano Gadlit using a tuba knife, which resulted in Gadlit’s death. Domen claimed he acted in self-defense. The prosecution’s evidence primarily relied on the testimony of the victim’s widow, who stated that Domen made an unprovoked attack at the foot of their stairway, witnessed by a neighbor, Angel Pocong. However, the court found the widow’s testimony unreliable, as Pocong himself testified that he was not present during the incident and only learned of it from the widow. The remaining prosecution evidence consisted only of testimony regarding Domen’s admission to the wounding and the fact of Gadlit’s death.

The defense presented witnesses, including Domen himself, who testified that Gadlit initiated the aggression by striking Domen multiple times with a piece of wood called a “Japanese,” approximately one vara in length and as thick as a wrist, following a quarrel over Domen’s carabao entering Gadlit’s cornfield. Domen stated that he did not retreat but instead struck back, wounding Gadlit on the forearm.

ISSUE:
Whether Urbano Domen is exempt from criminal liability on the ground of self-defense, specifically, whether there was reasonable necessity for the means he employed to repel the attack.

RULING:
The Supreme Court REVERSED the trial court’s judgment convicting Domen of homicide and ACQUITTED him on the ground of legitimate self-defense.

The Court held that the essential elements of self-defense were present:
1. Unlawful aggression on the part of the deceased, who attacked Domen with a dangerous piece of wood.
2. Reasonable necessity of the means employed to repel the aggression. The Court found that Domen’s use of a knife to wound Gadlit on the arma non-vital part of the bodywas proportionate and reasonably necessary under the circumstances. Domen did not provoke the assault, was where he had a right to be, and was faced with a sudden, violent attack.

The Court rejected the outdated common law “retreat to the wall” doctrine and adopted the “stand ground when in the right” rule, as articulated in Beard v. United States and Rowe v. United States. A person who is without fault and is violently assaulted is not obliged to flee but may stand his ground and use necessary force to protect himself from imminent danger to life or great bodily harm. Applying this principle, Domen had no duty to retreat and was justified in using force to defend himself during the ongoing struggle.

Accordingly, Domen was exempt from criminal liability. Costs were ordered de officio.

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