G.R. No. L-5291

THE UNITED STATES, plaintiff-appellee, vs. FACUNDO BARDELAS, defendant-appellant.

March 22, 1910

FACTS: On the night of June 2, 1908, in San Pablo, La Laguna, Facundo Bardelas fatally wounded Simeon Belen with a cutting weapon. Belen died a few hours later from severe hemorrhage caused by a stab wound on his left arm, which severed the humeral artery, veins, and median nerve.

According to prosecution witness Apolonio Manalo (Belen’s 16-year-old cousin), he and Belen were returning home when he saw Belen and Bardelas “quarreling.” Bardelas then fled, and Belen, wounded and holding a bloody bolo, asked Manalo for revenge before being taken to a nearby house where he later died. Another witness stated Belen identified Bardelas as his assailant before dying. A bloody bolo was found near Belen’s body.

Bardelas, however, claimed self-defense. He testified that Belen and Manalo confronted him on the road. Belen seized him by the shirt, questioned his destination, then grabbed him by the neck, squeezing it, and told Manalo to “strike him.” Manalo also encouraged Belen to strike Bardelas. Bardelas used his left hand to free himself from Belen’s grip. When Belen attempted to stab him, Bardelas blocked the blow with his left hand and, at the same time, struck Belen with a small penknife (8cm blade) before running away.

Upon reaching home, Bardelas noticed a cut on his left hand and a scratch on his neck. Medical examination two days later confirmed these injuries: a 2.5cm cut on the back of his left hand (skin-deep) and a 2.5cm scratch on his neck, both described as slight. Expert medical testimony suggested these injuries were likely caused by Belen’s attempted blow, possibly sustained while blocking the attack obliquely.

ISSUE: Whether Facundo Bardelas acted in lawful self-defense and is thus exempt from criminal responsibility.

RULING: Yes. The Supreme Court found that the three circumstances constituting lawful self-defense and exemption from criminal responsibility were duly proven.

The Court held that the evidence presented, particularly Bardelas’s account corroborated by his minor injuries which expert testimony deemed consistent with blocking a blow, demonstrated that he was unlawfully attacked by Simeon Belen. The immediate and unprovoked aggression from Belen, combined with Manalo’s encouragement and Belen’s attempt to strike Bardelas, justified Bardelas’s actions to defend himself. The means employed by Bardelas (a small penknife) were considered reasonably necessary to repel the aggression, given Belen’s use of a bolo and the combined aggression.

Therefore, the judgment of the lower court was reversed, and Facundo Bardelas was acquitted, with costs de oficio.