G.R. No. 260353 , February 08, 2023
RULIE COMPAYAN CAMILLO, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

On February 12, 2012, petitioner Rulie Compayan Camillo was working, delivering sacks of rice in Dipolog City. While he was carrying a sack of rice, Noel Angcla, who was drunk, suddenly boxed him. Rulie continued working, but Noel boxed him again. Rulie then put down the sack of rice and punched Noel’s nose and jaw, causing Noel to fall, hit the concrete pavement, and die. Rulie was charged with homicide. He pleaded self-defense. The Regional Trial Court convicted him of homicide, finding he acted in retaliation, not self-defense. The Court of Appeals affirmed the conviction, ruling the element of unlawful aggression was absent as the danger had ceased when Rulie put down the sack and retaliated, and the means he employed were not reasonably necessary given Noel’s intoxicated state and Rulie’s physical advantage.

ISSUE

Whether Rulie Compayan Camillo is guilty of homicide or whether he acted in valid self-defense.

RULING

The Supreme Court ACQUITTED Rulie Compayan Camillo. The Court ruled that he acted in complete self-defense. All requisites were present: (1) There was unlawful aggression from Noel, manifested through persistent, reckless, and taunting fist blows while Rulie was carrying a heavy load, creating a real and imminent danger from Rulie’s perspective. The aggression had not ceased. (2) The means employed—a single punch with his fist—was reasonably necessary to repel the unprovoked attack from a drunk and unruly aggressor. (3) There was no sufficient provocation on Rulie’s part, as he was merely performing his job. The Court emphasized that unlawful aggression is not limited to attacks with weapons and must be viewed from the circumstances as reasonably perceived by the accused at the time of the incident. The trial court and the CA erred in not recognizing the unlawful aggression from Rulie’s vantage point.