People v. Marasigan
REITERATIONFacts
The Antecedents: On March 24, 1927, during a feast in Sariaya, Tayabas, the accused Fermin Marasigan declined a cup of wine offered by the deceased Pedro de Chavez. This refusal was perceived as a slight by the deceased, leading to a discussion. Both parties left the house, with Marasigan descending first, opening his penknife, and picking up a club on the street. The deceased followed, overtook Marasigan, and prepared for combat. Marasigan struck the deceased with the club, and they engaged in a fistfight. During the struggle, Marasigan stabbed the deceased multiple times with his penknife, causing fatal wounds. The deceased died shortly after. Procedural History: The Court of First Instance of Tayabas found the accused Fermin Marasigan guilty of homicide and sentenced him to fourteen years, eight months, and one day of reclusion temporal, with indemnity and costs. The Petition: The accused appealed, alleging errors in the trial court's findings, particularly concerning the prosecution's witnesses, the origin of the aggression, and the denial of self-defense.
Issue(s)
Whether the suppression of testimony by the prosecution raises a presumption that it would be unfavorable to the prosecution. Whether the accused acted in self-defense when he inflicted fatal wounds upon the deceased. Whether the aggression originated from the deceased.
Ruling
The judgment of the Court of First Instance is affirmed. The accused is found guilty of homicide.
Ratio Decidendi
On the suppression of testimony: The Court held that the suppression by the fiscal of the testimony of some witnesses does not raise a presumption that their testimony would be unfavorable to the prosecution. The prosecution is not obliged to present all eyewitnesses; presenting a sufficient number to prove the occurrence of the act is adequate. The testimony of additional witnesses would have been cumulative evidence, and its omission does not give rise to the presumption of unfavorable evidence, citing United States vs. Gonzales. On the issue of self-defense and aggression: The Court found the appellant's contention of self-defense untenable. The facts established that the deceased's refusal to accept wine was perceived as a slight, leading to a confrontation. The accused armed himself with a penknife and a club before leaving the house. The deceased overtook the accused on the street, and both prepared for combat. The accused initiated the physical assault by striking the deceased with a club. The subsequent stabbing occurred during a reciprocal fight. The Court reiterated the principle that in a voluntarily accepted encounter or fight, the initial aggression is an incident of the fight itself and does not qualify as an unwarranted aggression that would justify self-defense, citing United States vs. Navarro and United States vs. Cortes. On the origin of aggression: The Court affirmed the trial court's findings that the aggression did not originate solely from the deceased in a manner that would justify self-defense. The accused's actions, including arming himself and the reciprocal nature of the fight, indicated a voluntary engagement in the combat, negating the element of unlawful and unexpected aggression required for self-defense.
Main Doctrine
The right of lawful self-defense cannot be validly set up by a person who voluntarily exposes himself to the consequences of a hand struggle with his adversary, as the first act of force in such a situation is considered an incident of the fight itself and not an unwarranted aggression that legalizes self-defense.