However, with Subtle Strike, you always pay 1B, and can get both effects: Give a target creature a +1/+1 counter, give a target creature -1/-1 until end of turn, or both. Will Malevolence, you only got to get +1/+1 on a creature. The counter is much more permanent.
Not only is this a decent combat trick in Limited, but I could see this being pretty good in Pauper on Magic Online. I'm not sure this is quite good enough for Standard, but it's good value for only 2 mana on a common. I'd definitely use this in Draft, that's for sure.