Benjamin Casas stabbed Elgio and Joel during a confrontation at a taho factory. He claimed self-defense. The Supreme Court ruled self-defense did not apply for three reasons: 1) Casas failed to prove unlawful aggression by Elgio or Joel, which is required for self-defense. 2) Casas was actually the initial aggressor, brandishing a knife first. 3) As the party initiating the attack with a deadly weapon, Casas could not claim unlawful aggression against him. Without proving unlawful aggression, his self-defense claim failed and his criminal liability remained.
Benjamin Casas stabbed Elgio and Joel during a confrontation at a taho factory. He claimed self-defense. The Supreme Court ruled self-defense did not apply for three reasons: 1) Casas failed to prove unlawful aggression by Elgio or Joel, which is required for self-defense. 2) Casas was actually the initial aggressor, brandishing a knife first. 3) As the party initiating the attack with a deadly weapon, Casas could not claim unlawful aggression against him. Without proving unlawful aggression, his self-defense claim failed and his criminal liability remained.
Benjamin Casas stabbed Elgio and Joel during a confrontation at a taho factory. He claimed self-defense. The Supreme Court ruled self-defense did not apply for three reasons: 1) Casas failed to prove unlawful aggression by Elgio or Joel, which is required for self-defense. 2) Casas was actually the initial aggressor, brandishing a knife first. 3) As the party initiating the attack with a deadly weapon, Casas could not claim unlawful aggression against him. Without proving unlawful aggression, his self-defense claim failed and his criminal liability remained.
Benjamin Casas stabbed Elgio and Joel during a confrontation at a taho factory. He claimed self-defense. The Supreme Court ruled self-defense did not apply for three reasons: 1) Casas failed to prove unlawful aggression by Elgio or Joel, which is required for self-defense. 2) Casas was actually the initial aggressor, brandishing a knife first. 3) As the party initiating the attack with a deadly weapon, Casas could not claim unlawful aggression against him. Without proving unlawful aggression, his self-defense claim failed and his criminal liability remained.
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JUSTIFYING CIRCUMSTANCES: SELF-DEFENSE
People vs. Casas
G. R. No. 212565 February 25, 2015 Facts: Accused-appellant Benjamin Casas was charged with the crime of Murder and Attempted Homicide under Articles 248 and 249 of the Revised Penal Code. The RTC and the CA convicted him of the crimes charged On December 24, 2007, between 1 to 2 o clock in the afternoon, Benjamin Casas, accompanied by a certain "Ron-Ron", went to a certain taho factory located at 313 F. Roman Street, San Juan City, looking for a certain Jesus. Failing to find the person he was looking for, Casas brandished a knife and stuck it into a pail used for making taho. Elgio, an employee of the taho factory, confronted him and asked him to get rid of the knife. This resulted to a heated argument and fistfight where later Casas regain the knife and stabbed Elgio twice. While in pursuit of Elgio, Casas run to Joel who tried to help the former with bamboo pole but however slipped and made him lying prostrate on the floor where he was stabbed twice by the latter. Casas managed to overtake Eligio, and stabbed him again on the stomach. Fearing that Casas would kill him, Eligio grabbed a plastic stool and hit Casas on the head with it, forcing the latter to drop the knife and cease the attack. Accused-appellant Casas admitted the stabbing of Elgio and Joel but interposed self-defense to justify his actions. Issue: Whether or not the justifying circumstance of self-defense should be given credence in this case. Ruling: NO. The justifying circumstance of self-defense should not be given credence in this case. Under Article 11 of The Revised Penal Code anyone who acts in defense of his person or rights do not incur criminal liability provided that the following circumstances concur: (1) Unlawful aggression; (2) Reasonable necessity of the means employed to prevent or repel it; (3) Lack of sufficient provocation on the part of the person defending himself. The Supreme Court ruled that the above-mentioned requirements were not present in this case. Casas failed to prove any unlawful aggression on the part of either Joel or Eligio, which is a condition sine qua non for the justifying circumstance of self-defense to obtain. As case law puts it, there can be no selfdefense unless the victim committed unlawful aggression against the person who resorted to self-defense. It was Casas who was actually the aggressor, as he was the one who wielded a knife, brought it to bear on Eligio, then on Joel as he lay prostrate, and again on Eligio as he was fleeing. Being the party initiating the attack, and overbearing with a deadly weapon, Casas cannot successfully claim that there was unlawful aggression. Thus, given that the core element of unlawful aggression was not proven, Casass claim of selfdefense falters and his criminal liability stands.
SPRING HOMES SUBDIVISION CO., INC., SPOUSES PEDRO L. LUMBRES AND REBECCA T. ROARING, Petitioners, v. SPOUSES PEDRO TABLADA, JR. AND ZENAIDA TABLADA, Respondent.