US vs. Jose Laurel                                                                                                                                                        (22 Phil. 252)

FACTS: On the night of December 26, 1909, while the girl Concepcion Lat was walking along the street accompanied by several young people, including Exequiel Castillo, they’re on their way from the house of the latter, situated in the pueblo of Tanauan, Province of Batangas. Concepcion was approached by Jose Laurel who suddenly kissed her and immediately ran off in the direction of his house, pursued by Lat’s companions among them was Exequiel Castillo, but they did not overtake him.
On the second night after the occurrence, early evening of 28th of December, Jose Laurel with several young people went to parochial building for the purpose of attending an entertainment program.  While sitting in the front row of the chairs, and watching the said program, Jose Laurel was approached by Domingo Panganiban who told him that Exequiel Castillo wished to speak with him, Laurel replied that he should wait a while and Panganiban went away. A short time afterwards, he was also approached by Alfredo Yatco who gave him a similar message, and afterwards Felipe Almeda came up and told him that Exequiel Castillo was waiting for him on the ground floor of the building.
This being the third summons addressed to him, he arose and went down to ascertain what Exequiel Castillo wanted. When they met, Castillo asked Laurel why he kissed Concepcion Lat (Castillo was Lat’s current suitor). Laurel replied that he had done so because she was very fickle and prodigal of her use of word “yes” on all occasions, Exequiel Castillo said to him that he ought not to act that way and immediately struck him a blow on the head with a cane or club, which assault made Laurel dizzy and caused him to fall to the ground in a sitting posture and that, as Laurel feared that his aggressor will continue to assault him, he took of the pocketknife which he was carrying in his pocket and therewith stabbed Exequiel. Among the wounds inflicted on Exequiel, the wound on the left side of his  breast penetrated the lungs causes him to spit blood. He would have died, had it not been for the timely medical aid rendered.

ISSUE: Is Justifying circumstance of Self- defense valid on the part of Jose Laurel?

HOLDING: The court ruled in view of the findings of facts the defendants are acquitted and exempted from all responsibility. Lack of sufficient provocation on the part of Laurel, who did not provoke the occurrence, nor did he direct that Exequiel Castillo be invited to come down from the parochial building and to clarify the last incident which Castillo was alone interested, and because in defending himself, Laurel used his pocketknife against the assault made upon him with a cane or club, which may also be a deadly weapon, employed reasonable means to prevent or repel the same. By the three requisites of Unlawful aggression on the part of Exequiel Castillo the defensive act executed by Jose Laurel was justified.

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