G.R. No. 213273.
June 27, 2018
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. LEONARDO B. SIEGA, ACCUSED-APPELLANT.
Facts:
On the 16th day of October 2005 at around 4:30 p.m., Siega was about to enter his house when he heard
a sound coming from the feeder road facing his residence. When Siega looked where the noise was
coming from, he saw Bitoy, rushing towards and shouting towards him saying that he should get out his
house so they could settle there grudges between each other. As Bitoy was nearing him, Siega saw the
former attempting to draw the bolo that was wrapped on his waist. Scared by Bitoy's actions, Siega
immediately grabbed unto the bolo that was then beside him and hacked Bitoy. Siega inflicted several
injuries on Bitoy, before the latter retreated and ran away. Siega then went inside his house, changed his
clothes, and surrendered to the authorities. However, Siega pleads self-defense.
The RTC found Siega guilty beyond reasonable doubt of the crime of Murder. The CA affirmed the RTC’s
ruling.
Issue:
Is their merit to Siega’s plead of Self Defense?
Held:
In pleading self-defense, it is essential that there is an unlawful aggression on the part of the victim.
Unlawful aggression refers to "an actual physical assault, or at least a threat to inflict real imminent
injury, upon a person." Without unlawful aggression, the justifying circumstance of self-defense has no
leg to stand on and cannot be appreciated.
In the case at bat, Siega failed to establish unlawful aggression on the part of the victim, Bitoy. Bitoy's
supposed act of holding a weapon from his waist does not constitute unlawful aggression, as it does not
pose any actual, sudden, or imminent danger to the life and limb of Siega. Absent unlawful aggression,
Siega’s claim of self-defense must necessarily fail.