Title
Caluag vs. People
Case
G.R. No. 171511
Decision Date
Mar 4, 2009
Caluag convicted for mauling Nestor Denido and threatening Julia with a gun; SC upheld lower courts' rulings based on credible testimonies and sufficient evidence.

Case Digest (G.R. No. 171511)
Expanded Legal Reasoning Model

Facts:

  • Procedural History
    • Two Informations were filed on May 18 and 23, 2000, as Criminal Cases Nos. 47381 (slight physical injuries) and 47358 (grave threats) against Ronnie Caluag and Jesus Sentillas before the Metropolitan Trial Court (MeTC) of Las Piñas City, Branch 79.
    • Upon plea of not guilty, joint trial ensued. On January 28, 2004, the MeTC found both accused guilty of slight physical injuries and Caluag also guilty of grave threats.
    • On August 3, 2004, the Regional Trial Court (RTC), Branch 198, Las Piñas City, affirmed the MeTC decision. The Court of Appeals (CA) likewise affirmed on December 9, 2005, and denied reconsideration on February 15, 2006.
    • Caluag filed a petition for certiorari under Rule 45 before the Supreme Court, challenging the sufficiency and credibility of the evidence.
  • Factual Antecedents
    • Complainants’ Version
      • On March 19, 2000 at around 4:00 p.m., Nestor Denido learned two guests had been mauled. He approached Caluag and Sentillas, who were drinking, and was suddenly boxed by Caluag, then overpowered by both men. Julia Denido attempted to intercede.
      • At about 7:30 p.m., while en route to report the mauling to barangay authorities, Julia was confronted by Caluag, who pointed a gun at her forehead and said in Tagalog, “Saan ka pupunta, gusto mo ito?” She proceeded to the barangay hall and reported the incident.
    • Defense Version
      • Caluag testified that Nestor, drunk and blocking his path, punched him first after persistent taunts, prompting Caluag to defend himself. By­standers intervened; Jesus Sentillas did not assault Nestor.
      • Caluag denied ever pointing a gun at Julia or making any threat. An independent witness, Pablo Barrameda Jr., corroborated that Caluag was attacked first by Nestor and saw no gun-poking incident.

Issues:

  • Whether there was sufficient evidence to sustain the convictions for slight physical injuries and grave threats.
  • Whether the lower courts erred in crediting the testimonies of the private complainants over the defense witnesses.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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