PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee v. CRISTINA SAMSON, Accused-Appellants.

G.R. No. 214883, September 02, 2015

FACTS

Cristina Samson and Gerry Delmar were married and had two daughters, namely, Christine and Cherry
Lou Delmar. According to the appellant, she was watching television together with their children when
her husband arrived drunk. He then scolded and slapped her upon her reply that she had not cooked their
food yet. Her father arrived and pacified them. Gerry left but returned 30 minutes after, pointed a knife at
Cristina’s neck, and slapped her twice. She pushed him to the ground, took the knife he was holding, and
begged for him not come near her. But he grabbed her, and so the knife went in contact with his chest.
After seeing her husband covered in blood, she shouted for help. Her father and brother came to bring
him to the hospital. Eventually, Gerry died at the hospital. However, there appears to be a conflict
between the testimony of Cristina and her daughter, Christine. The latter narrated that as the fight
escalated, her mother was able to get hold of the knife which was inserted in the roof and stabbed her
father. He fell to the ground and crawled until he reached the door. People arrive to help bring his father
to the hospital, while her mother then ran out and went to ask money from her father before leaving. That
was the last time Christine and Cherry Lou saw their mother. The appellant pleaded not guilty and
invoked the justifying circumstances of self-defense. Though the Regional Trial Court (RTC) and Court
of Appeals (CA) believed the version of Cristina, they still found her guilty of parricide because though
there could have been an unlawful aggression at the start, it already ceased when the victim put down the
knife. Hence, this present appeal to review the decision of the CA.

ISSUE
Whether or not the accused may invoke self-defense as a justifying circumstance to escape criminal
liability
RULING
In order to invoke self-defense to escape criminal liability, it is incumbent upon the accused to prove by
clear and convincing evidence the concurrence of the following requisites under Article 11 of the Revised
Penal Code: (1) unlawful aggression; (2) reasonable necessity of the means employed to prevent or repel
it; and (3) lack of sufficient provocation on the part of the person defending himself.
The Supreme Court viewed that there was unlawful aggression when Cristina killed her husband, and the
said aggression continued even when he was disarmed. After Cristina was able to take hold of the knife,
Gerry still continued to move towards her despite of her plea. He grabbed her which could have
precipitated her well-grounded belief that her life was still in danger. Cristina did not have the time or
sufficient tranquility of mind to choose a weapon so she grabbed the knife after finding no other available
means or any less deadly weapon to repel the threat. In addition, Cristina’s act of shoving Gerry cannot be
considered a sufficient provocation for she merely acted on an opportunity to save herself from what she
had perceived to be a danger in her life.
WHEREFORE, the appeal is GRANTED. The May 6, 2014 Decision of the Court of Appeals, in CA-
G.R. CR HC No. 05832, is REVERSED and SET ASIDE. The accused-appellant, Cristina Samson, is
ACQUITTED of the crime charged.