CASE DIGEST: G.R. No. L-3. Promulgated: January 29, 1946

 THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOSE ANSOYON, defendant-appellant.

Crime: Homicide, Self-Defense

Law: Criminal Law

Cited Jurisprudence: None

Cited Law/Order: Revised Penal Code (Article 249)

Famous statement from this jurisprudence:

To avoid criminal liability of the appellant, he must prove the justifying circumstance claimed by him — self-defense — to the satisfaction of the court by relying on the strength of his own evidence and not on the weakness of that of the prosecution.

FACTS:

Jose Ansoyon inflicted six stab wounds on Jesus Marasigan in the left side of the chest which cut the lower part of the heart.

ISSUE:

The only question to decide is whether Ansoyon did so in self-defense.

RULING:

            The Supreme Court cannot believe that:

1. the deceased could still struggle with his assailant not only to retain the possession of his own weapon but also to seize after receiving the mortal wound in the left side of the chest, which cut the lower part of the heart

2. the deceased had a revolver at that time, pulled it, aimed it at the appellant, never fired it nor made any other use of it to defend himself against the determined attack of his adversary, armed with a fan-knife and claims that he was forced to pull it from his hip pocket and open it and plunge it into the left side of the breast of the deceased after the latter had aimed his revolver.

3. Deceased would not at least use its barrel or handle to parry the blows of his adversary

4. repeatedly stabbed and killed Jesus Marasigan

It certainly would have taken the deceased much shorter time to pull the trigger of the revolver than the appellant to pull out his fan-knife from his hip pocket and open it.

The Supreme Court believe that: deceased block the successive blows of his adversary with his bare hand after he had received the stab wound in the back and before he fell and received the mortal wound in the left side of his chest

To avoid criminal liability of the appellant, he must prove the justifying circumstance claimed by him — self-defense — to the satisfaction of the court by relying on the strength of his own evidence and not on the weakness of that of the prosecution.

Hence, he cannot escape the penalty for homicide imposed by article 249 of the Revised Penal Code.

Lesson of this case:

Accused is in burden of proof in criminal cases. His evidence matters, not the evidence of any other person/party. Accused must provide strong evidence against the prosecution and the witness.

Full text of the case: https://www.lawphil.net/judjuris/juri1946/jan1946/gr_l-3_1946.html