## **Facts:**
1. On May 7, 2006, around midnight, Romeo Arca, seemingly inebriated, forcibly entered the home of Rodolfo Olarbe in Sitio Pananim, Luisiana, Laguna, armed with a rifle converted to a caliber .22 and a bolo.
2. Arca fired the rifle and shouted insults and threats towards Olarbe and his wife, who were asleep but awoken by the chaos.
3. Olarbe wrestled the rifle away from Arca and shot him in the head.
4. Despite the shot, Arca drew his bolo, and a struggle ensued between Arca and Olarbe, which led them outside the house.
5. Olarbe managed to gain control of the bolo and used it to hack Arca, resulting in Arca’s death.
6. Olarbe immediately surrendered to local authorities, reporting the incident, and was detained.
7. Arca’s death certificate indicated gunshot wounds and several hacking wounds as the causes of death.
## **Procedural Posture:**
1. The Regional Trial Court (RTC) of Santa Cruz, Laguna (Branch 27) convicted Olarbe of murder, rejecting his defense of self-defense and defense of stranger. He was sentenced to 20 years and one day to reclusion perpetua and ordered to pay damages to Arca’s heirs.
2. Upon appeal, the Court of Appeals (CA) affirmed the RTC’s decision with a minor modification, ordering Olarbe to pay temperate damages and adding interest on the civil indemnity, moral, exemplary, and temperate damages.
3. Following the affirmance by the CA, Olarbe appealed to the Supreme Court, arguing the rejection of his self-defense and defense of stranger pleas was erroneous.
## **Issues:**
1. Whether the RTC and CA erred in rejecting Rodolfo Olarbe’s pleas of self-defense and defense of a stranger.
2. Whether the elements of self-defense and defense of stranger were sufficiently proven by Olarbe.
3. Whether the inflicted wounds indicated a reasonable necessity for the means employed to repel the unlawful aggression.
## **Court’s Decision:**
The Supreme Court found merit in Olarbe’s appeal.
### **On Self-Defense and Defense of Stranger:**
1. **Unlawful Aggression:**
– It was determined that Romeo Arca’s actions constituted continuous and persistent unlawful aggression. Arca’s aggressive conduct—from forcibly entering Olarbe’s home with a gun, firing it, and issuing death threats, to later charging at Olarbe’s wife with a bolo—presented a clear and imminent danger to Olarbe and his spouse.
– The Court found it implausible and speculative for the lower courts to assume that Arca was too weak to continue his aggression after being shot in the head, citing the natural adrenaline and persistence in such attackers.
2. **Reasonable Necessity of Means:**
– The court articulated that “reasonable necessity” does not imply a perfect or least aggressive counterattack but rather a rational equivalence considering the imminent danger.
– The gunshot wound and multiple lacerations indicated an intense and persistent conflict which justified Olarbe’s defensive actions. The extent and nature of the wounds did not convincingly demonstrate an excessive response by Olarbe given the immediate peril he faced.
3. **Lack of Sufficient Provocation:**
– The evidence showed that Arca’s aggression was unprovoked by Olarbe, who was defending against a forcible, armed intrusion into his home.
### **Acquittal:**
– Taking into account Olarbe’s immediate surrender to authorities post-incident, which indicated a consciousness of having acted within justifiable bounds, the Supreme Court acquitted Olarbe.
– The Supreme Court emphasized the context of the situation, recognizing that Olarbe acted in earnest belief of threat to life and in defense of his spouse.
## **Doctrine:**
– **Self-Defense and Defense of Stranger:**
– Discerning the justifying circumstances for self-defense and defense of a stranger hinges on evaluating the accused’s perspective and the imminent threat perceived during the incident, not on an objective hindsight.
## **Class Notes:**
– **Article 11 of the Revised Penal Code:**
– **Self-defense:** Requires an unlawful aggression, reasonable necessity of the means to repel such aggression, and lack of provocation by the defender.
– **Defense of Stranger:** Involves unlawful aggression against another, reasonable necessity of the means to prevent or repel it, and the defender not being motivated by revenge or similar motives.
– **Unlawful Aggression:** Must be actual or imminent and unlawful in nature—prompting immediate defensive action.
– **Immediate Danger:** Evaluation based on the circumstances as perceived by the defender at the time of the incident.
– **Reasonable Necessity:** Does not demand absolute necessity but rational means adequate to counter the threat within the context encountered.
## **Historical Background:**
– Historically, Philippine jurisprudence interprets justifying circumstances through the subjective eyes of the defender, allowing a nuanced application reflecting immediate peril and instinctive actions in moments of life-threatening danger.
– This decision underscores adherence to the tenet that imminent threat judged from the defender’s standpoint is paramount, bolstering case law favoring preservation instincts in dire situations.
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