or 2 units of the same level ... and maybe you see Orange ogre hit White ogre first, but white ogre wins the batter... and then wonder why?
i'm like 99% sure whoever is further along in tech (upgrading to lvl 2) wins the battle, even though it's not actually lvl 2 yet.
i havent tested it, but i bet when 2 peons fight the way the winner is determined is by who has more peons (i could be wrong on that one though)