G.R. No. 40597 ; September 28, 1933
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. IGNACIO MACASPAC and RAFAEL PAULE, defendants-appellants.

FACTS

The appellants lived on land owned by the deceased, Silvino Sabado. After Rafael Paule’s horses destroyed the deceased’s crops, a confrontation occurred. According to the prosecution, Ignacio Macaspac arrived and immediately stabbed the deceased with a penknife, causing fatal wounds. The defense claimed the deceased first struck Macaspac with a bolo, prompting Macaspac to retaliate with the penknife. The trial court found both guilty of homicide, sentencing Macaspac as principal and Paule as accomplice.

ISSUE

Whether the appellants are guilty of the crime of homicide, specifically: (1) if Macaspac can invoke self-defense, and (2) if Paule is liable as an accomplice.

RULING

The Supreme Court affirmed Macaspac’s conviction but acquitted Paule.
1. As to Macaspac: The Court found the evidence supported the conclusion that the deceased and Macaspac had mutually agreed to fight. Both were armed and cautiously advancing toward each other before the aggression. In such a mutual combat, the fact that the deceased started the aggression is immaterial and cannot support a plea of legitimate self-defense. The fight is deemed accepted by both from the outset. Macaspac’s sentence was modified under the Indeterminate Sentence Law to a range of seven years of prision mayor (minimum) to twelve years and one day of reclusion temporal (maximum).
2. As to Paule: The evidence was insufficient to prove beyond reasonable doubt that Paule held the deceased to enable Macaspac to stab him. His intervention, as stated in his affidavit, was to separate the combatants. Therefore, he was acquitted.

AI Generated by Armztrong.