Thursday, January 29, 2009

JAYME VS PEOPLE 314 SCRA 117



Facts:
On May 25, 1992 at around 7:00 pm, the petitioner was on his way home while carrying a pail of water when suddenly complainant Ramil Cruz blocked his way and attacked him with fist blows. Cruz was with his brothers and three other persons. Surprised at the sudden attack, Jayme drew a knife and used it against Ramil. The other three persons joined Ramil in attacking and one hit him on his head, causing him to drop the knife. He then ran away. His head injury was duly proved.


Issue: Whether or not the petitioner employed reasonable means to repel the attack.


Held: Reasonable means does not mean absolute necessity. It must be assumed that one who is assaulted cannot have sufficient tranquility of the mind to think and make comparisons, which can be made in the calmness of the home. The rule of reasonable necessity is not ironclad in its application. It depends on the circumstances of the particular case. Under the present situation, in the darkness of night, the element of surprise in the assault, the perception that the aggressor was armed and that three or more persons were ganging up on him, gave the accused reasonable cause to use his weapon which was his only means of defense. In emergencies of this kind, human nature does not act upon processes of formal reason but according to the instinct of self-preservation. For having duly proved all the essential elements of self-defense, the accused is entitled to an acquittal.

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