**Facts:**
1. On November 24, 1913, in San Pablo, Laguna, Casiano Banzuela and Anselmo Banzuela were accused of killing Carlos Violan using a dagger, pocket knife, and monkey wrench.
2. A complaint was filed on February 14, 1914, by the provincial fiscal in the Court of First Instance of Laguna, charging both Banzuelas with homicide.
3. A preliminary investigation was held in San Pablo where the justice of the peace found Anselmo Banzuela not guilty due to insufficient evidence.
4. Despite Anselmo’s release, the fiscal objected to exclusion from proceedings, leading to a contested legal motion regarding his right to a preliminary investigation.
5. The Court of First Instance denied Anselmo’s motion for exclusion from the proceedings and subsequent request for a preliminary investigation, based on the fiscal’s original complaint.
6. At trial, both defendants waived arraignment and pleaded not guilty.
7. The trial court found both defendants guilty, sentencing them to 14 years, 8 months, and 1 day of reclusion temporal, along with accessory penalties and damages to the victim’s family.
8. The defendants appealed the decision on several grounds, including errors concerning procedural due process and self-defense justification for Casiano.
**Issues:**
1. Was Anselmo Banzuela entitled to a preliminary investigation despite the earlier finding of innocence by the justice of the peace?
2. Did the trial court err in proceeding against Anselmo without a proper preliminary investigation?
3. Was Casiano Banzuela justified by lawful self-defense in the killing of Carlos Violan?
4. Were the defendants entitled to the benefit of reasonable doubt in their conviction?
**Court’s Decision:**
1. **Preliminary Investigation for Anselmo Banzuela:** The Supreme Court held that the absence of a preliminary investigation for Anselmo Banzuela was erroneous. As the original investigation did not result in Anselmo being remanded to Court because the justice of the peace determined no reasonable ground for prosecution, he was deprived of due process. Therefore, the proceedings against Anselmo were declared void.
2. **Lawful Self-defense for Casiano Banzuela:** The court found that Casiano’s act was not justified by self-defense. After a prior altercation during which Violan had wounded Casiano, the subsequent fight where Violan was killed was initiated mutually without immediate unlawful aggression from Violan, disqualifying a self-defense claim.
3. **Reasonable Doubt:** The testimonies provided by witnesses and the evidence on record were sufficient for the trial court to conclude beyond a reasonable doubt that Casiano was guilty of homicide.
**Doctrine:**
1. Preliminary Investigation: A defendant is entitled to a preliminary investigation showing reasonable grounds before being deprived of liberty or subjected to trial.
2. Lawful Defense: For self-defense to justify homicide, there must be unlawful aggression, necessity of the means to prevent or repel it, and lack of sufficient provocation by the defender.
**Class Notes:**
– **Preliminary Investigation:** As enshrined in Philippine law, the right to be free from arrest and trial without a preliminary investigation (Secs. 13-14 of General Orders No. 58; Sec. 1-2, Act No. 194).
– **Self-defense:** Article 8, No. 4 of the Penal Code requires unlawful aggression, necessity, and lack of provocation.
– **Homicide Elements:** An unlawful killing of a person not amounting to murder, with or without intent to use a lethal weapon.
**Historical Background:**
The case occurred during the American colonial period in the Philippines, showcasing the transition of legal principles influenced by American jurisprudence. It reflects early 20th-century procedural challenges in adapting new criminal procedure laws, emphasizing due process and the right to preliminary investigations, elements not as rigorously enforced during Spanish rule.
This case highlights the evolving criminal justice system and sets a precedent on procedural rights prior to trial, as well as clarifications on self-defense justifications under the Penal Code.
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