Daniel Aquino y Espiritu v. People

Summary

Petitioner Daniel Aquino was charged and convicted of homicide for stabbing Lorvin Cordovez during a brawl at a construction site. The lower courts held that Aquino failed to prove the reasonable necessity of the means employed, characterizing the act as incomplete self-defense. However, the Supreme Court reversed this decision, acquitting Aquino on the ground of complete self-defense. The Court found that Lorvin's actions—pursuing Aquino, initiating a fight, and pinning him to the ground while strangling and punching him—constituted actual unlawful aggression. The Court emphasized that the requirement of 'reasonable necessity' does not demand absolute necessity or perfect calm, but rather rational necessity viewed from the standpoint of the person under attack. Since Aquino acted out of an instinct for self-preservation to repel a real and palpable peril to his life, the justifying circumstance of self-defense applies, absolving him of both criminal and civil liability.