G.R. No. L-2650

FACTS:
The defendant-appellant, Pedro Tolosa, was convicted by the trial court of the crime of homicide for inflicting fatal wounds upon the deceased. He was sentenced to reclusion temporal and ordered to pay indemnity. On appeal, the Solicitor-General recommended acquittal, contending that Tolosa acted in self-defense. The evidence for the defense, consisting of Tolosa’s testimony corroborated by two eyewitnesses, established that the deceased initiated an unprovoked and unlawful aggression by striking and kicking Tolosa, knocking him to the ground, and then continuing the attack with a heavy piece of bamboo. To repel this ongoing aggression, Tolosa drew a pocketknife and wounded the deceased, resulting in his death. The prosecution presented no eyewitnesses to contradict this account. The trial court had relied heavily on Tolosa’s initial plea of “guilty” during the preliminary investigation.

ISSUE:
Whether or not the defendant acted in legitimate self-defense, thereby exempting him from criminal liability.

RULING:
Yes. The Supreme Court reversed the judgment of conviction and acquitted the defendant. The Court found the testimony of the defense witnesses, which remained uncontradicted by any prosecution evidence, to be credible and sufficient to establish the elements of self-defense. The deceased was the unlawful aggressor, and Tolosa’s use of a knife was a necessary means to repel the serious attack with a bamboo club. The Court clarified that Tolosa’s initial plea of “guilty” at the preliminary investigation was merely an admission that he inflicted the wounds, not a judicial confession of criminal guilt, as he subsequently pleaded not guilty and fully explained the justifying circumstance of self-defense at trial. Consequently, having acted in legitimate self-defense, Pedro Tolosa incurred no criminal liability and was ordered released.