G.R. No. L-3970

THE UNITED STATES, plaintiff-appellee, vs. BONIFACIO BUNSALAN, defendant-appellant.

January 14, 1908

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FACTS:

On February 1, 1906, Celestino Prado, who was in charge of a fish pond belonging to Gregorio Sajo and had an interest in its proceeds, went to Sajo’s house to confront him for selling the fish at an excessively low price without his consent. Sajo took offense and called some of his laborers, including Bonifacio Bunsalan, to detain Prado when he left. As Prado exited, he was attacked by Bunsalan with a bolo, sustaining wounds to his right forearm and left shoulder. Other laborers of Sajo joined Bunsalan in the assault. Prado defended himself with his own bolo, which he had recovered from where he left it near the staircase, and in turn wounded Bunsalan. Prado then fled, eventually falling down a kilometer away, where he was found with several wounds, requiring 45 days to recover but resulting in no serious injury or incapacity. Bunsalan also suffered wounds requiring 45 days to heal.

A complaint for mutual lesiones graves (serious physical injuries) was filed against both Prado and Bunsalan. The Court of First Instance (CFI) found Bonifacio Bunsalan guilty of lesiones graves and sentenced him to one year and one day of prision correccional. The CFI acquitted Celestino Prado, ruling that he acted in self-defense, finding that he was alone and attacked by Sajo’s armed men, thus making a lawful defense. Bonifacio Bunsalan appealed the judgment.

ISSUE:

The sole issue for the Supreme Court’s determination was which of the two, Bonifacio Bunsalan or Celestino Prado, was the aggressor and who lawfully defended himself against the aggression.

RULING:

The Supreme Court AFFIRMED the judgment of the Court of First Instance, finding Bonifacio Bunsalan guilty of lesiones graves and acquitting Celestino Prado on the ground of self-defense.

The Court held that the evidence clearly showed Bonifacio Bunsalan was the aggressor. It noted that Prado, despite his annoyance, had no initial intention to cause harm as he left his bolo outside the house before remonstrating with Sajo. It was Sajo who, offended by Prado’s reproaches, sent for his laborers, including Bunsalan, to detain Prado. Upon Prado’s exit, Bunsalan attacked him with a bolo.

The Court agreed with the CFI’s assessment of the witnesses, finding Bunsalan’s witnesses to lack veracity and to be eager to shift blame to Prado. Conversely, Prado’s account was credible, supported by the circumstances, including the fact that he was attacked by Sajo’s armed men.

Therefore, the Court concluded that Prado, when wounding Bunsalan, did so in complete self-defense, fulfilling all the requisites of an exempting circumstance under Article 8, No. 4 of the Penal Code (then in force). Bunsalan’s claim of self-defense was deemed inexplicable, as there was no prior quarrel or provocation from Prado.

Accordingly, Bonifacio Bunsalan was held solely liable for the crime of lesiones graves committed against Celestino Prado. The sentence of one year and one day of prision correccional was affirmed, along with the accessory penalties prescribed by law and costs.