PEOPLE vs.

ARIES SANTOS
G.R.No. 232244
Second Division
DOCTRINE: Self-Defense is perched in proof of Unlawful Agression on the part of the victim.
Without it, there can be no Self-Defense, complete or incomplete.
FACTS:
Aries Santos was guilty of the crime of murder for killing the victim using a knife. Santos argues
that he acted in self-defense.
ISSUE: Whether the claim of incomplete self-defense will prosper.
RULING: No. accused-appellant asserts that he acted in self-defense. When the accused
interposes self-defense, he must prove that: 1.he was not the aggressor; 2.there was lack of
sufficient provocation on his part; 3.he employed reasonable means to prevent or repel the
aggression. The most important element of which is unlawful aggression.
Accused-appellant claims that he was passing by the victim’s house and that upon seeing him,
the victim approached him while holding a knife. The victim tried to lunge at him so he stepped
back but the victim continued to move towards him. He got hold of the victim’s arms and the
latter lost hold of the knife. The said knife dropped to the ground, and near their feet. Assuming
arguendo that the following assertions were true, it can be said that the supposed unlawful
aggression that accused-appellant was trying to describe, already ceased. There was no more
unlawful aggression to speak of at that moment.
Therefore, it follows then that the claim of incomplete self-defense will not prosper because
there was no unlawful aggression. The Supreme Court agrees with the Court of Appeals and the
Regional Trial Court that the physical evidence based on the nature and the number of injuries
sustained by the victim negate self-defense. A plea of self-defense is belied by the nature,
number, and location of the wounds inflicted on the victim since the gravity of said wounds is
indicated of a determined effort to kill and not just to defend.