GR L 13314; (March, 1918) (Digest)
G.R. No. L-13314; March 13, 1918
THE UNITED STATES, plaintiff-appellee, vs. JUAN DINOLA, defendant-appellant.
FACTS:
On January 31, 1917, in Alangalang, Leyte, the defendant Juan Dinola was carrying ₱5.00 when he passed by a house where a festival was being held. His cousin, Guillermo Dinola (the deceased), asked if he had money. Juan replied that he did, intending to pay laborers. Guillermo then requested the money, explaining that he had lost in gambling and needed to repay a debt, fearing his wife’s anger. When Juan showed the money, Guillermo attempted to seize it. A struggle ensued, during which Guillermo grabbed Juan’s thumb with his left hand, drew a penknife with his right hand, and stabbed Juan in the shoulder and belly. As Juan retreated to a partition wall, Guillermo released the money and grabbed his throat. Believing his life was in danger, Juan used his own knife (which he carried for distilling tuba) and stabbed Guillermo in the stomach. Guillermo momentarily released him but attacked again; Juan continued to defend himself, inflicting additional wounds. When Guillermo cried for help, Juan asked for forgiveness, left the scene, and surrendered to the police. The only eyewitness, Isidro Tañada, was not presented in court. The defendant’s testimony remained uncontradicted.
ISSUE:
Whether the defendant acted in lawful self-defense, thereby exempting him from criminal liability for the death of Guillermo Dinola.
RULING:
Yes. The Supreme Court reversed the trial court’s judgment and acquitted Juan Dinola. The Court held that when the defendant’s testimony is uncontradicted and the facts declared are likely, such testimony should be accepted. The defendant’s account established the elements of self-defense: (1) unlawful aggression by the deceased, who initiated the attack with a knife; (2) reasonable necessity of the means employed, as Juan used a similar weapon to repel the assault; and (3) lack of sufficient provocation on the defendant’s part. The trial court’s reasons for rejecting the defendant’s testimonyalleged contradictions in minor details and the failure to present an eyewitnesswere deemed insufficient. The presumption that omitted evidence is adverse does not apply to merely corroborative evidence available to both parties. Thus, Juan Dinola acted in self-defense and is exempt from criminal liability. He was ordered released immediately.
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