G.R. No. L-7037, March 15, 1912
THE UNITED STATES, plaintiff-appellee, vs. JOSE LAUREL, ET AL., defendants-appellants.

FACTS

On the night of December 26, 1909, Jose Laurel kissed Concepcion Lat, who was being courted by Exequiel Castillo, causing resentment. Two nights later, during a town entertainment, Domingo Panganiban facilitated a meeting between Castillo and Laurel to discuss the incident. A quarrel ensued between Castillo and Laurel in the yard of the parochial building. During the altercation, Castillo was seriously wounded with multiple stab and contusion injuries, while Laurel sustained slight head wounds. The prosecution presented Castillo’s version where he was suddenly attacked by Laurel with a knife, then assaulted by Vicente Garcia, Conrado Laurel, and Panganiban. The defense presented a contradictory version where Castillo was the aggressor, attacking Laurel with a cane, and Garcia and Conrado Laurel only intervened to defend their cousin Laurel from Castillo’s assault.

ISSUE

Whether the defendants (Jose Laurel, Vicente Garcia, Conrado Laurel, and Domingo Panganiban) are criminally liable for the serious physical injuries inflicted upon Exequiel Castillo.

RULING

No. The Supreme Court ACQUITTED all defendants. The Court found the evidence for the defense more credible. It held that Jose Laurel acted in self-defense under Article 8(4) of the Penal Code, as he was unlawfully aggressed upon by Castillo, who attacked him with a cane. The means Laurel employed (using a knife) were reasonably necessary to repel the attack. Vicente Garcia and Conrado Laurel likewise acted in lawful defense of their relative, Jose Laurel, under Article 8(5), as they intervened to prevent further harm to him after seeing him assaulted by Castillo. There was no evidence that they provoked the incident. As for Domingo Panganiban, the testimony of a prosecution witness (Primitivo Gonzalez) corroborated his claim that he did not participate in the fight and remained at a distance. Therefore, none of the defendants incurred criminal liability. The appealed judgment of conviction was reversed. Costs de oficio.