Case Digest (G.R. No. 237334)
Facts:
In CICL XXX v. People of the Philippines and Glenn Redoquerio (G.R. No. 237334, decided November 16, 2020 under the 1987 Constitution), a Criminal Case was filed in the Regional Trial Court (Quezon City, Branch 94) charging the 17-year-old minor, identified as CICL XXX, with Frustrated Homicide. The Information alleged that on January 1, 2010 at around 12:30 a.m. in Quezon City, CICL XXX, acting with discernment and in conspiracy with Christopher Puyo and Jayjay Narag, attempted to kill Glenn Redoquerio by firing a handgun (which misfired) and striking him repeatedly with the weapon and a stone, inflicting grave wounds that placed the victim in a coma for seven days. The prosecution presented the victim and an eyewitness, Michael de los Santos, whose testimonies identified CICL XXX as the assailant. Medical records from East Avenue Medical Center were offered through the hospital’s administrative officer under stipulation that he could not testify as to the nature or fatality ofCase Digest (G.R. No. 237334)
Facts:
- Criminal Information and Arraignment
- On January 1, 2010, in Quezon City, the Information charged CICL XXX, a 17-year-old minor, with frustrated homicide for conspiring with Christopher Puyo and Jayjay Narag to maul Glenn Redoquerio, striking him with a stone and a gun such that all acts of execution for homicide were done but did not produce death due to timely medical care.
- During arraignment, CICL XXX pleaded not guilty; pre-trial and trial thereafter ensued.
- Prosecution’s Evidence
- Glenn Redoquerio testified that at about 12:30 AM, he was buying iced tea powder when CICL XXX threatened him with a gun, pulled the trigger (which misfired), then hit him on the head with the gun; Puyo and Narag held Redoquerio while CICL XXX punched him, and Puyo struck him with a stone, causing a seven-day coma and medical expenses.
- Michael de los Santos corroborated the attack. Through stipulation, Reginaldo Luague, Administrative Officer I at East Avenue Medical Center, authenticated medical records (Exhs. F–F-1, I–I-1, J–J-1, K–K-1, L–L-1) but could not testify as to the nature, gravity, or fatality of the wounds.
- Defense’s Evidence
- CICL XXX denied participation, stating he was home celebrating New Year at 2:00 AM, only witnessing a mauling of Narag by Redoquerio and de los Santos before returning home at his mother’s call.
- He claimed mistaken identity and lack of motive for Redoquerio to name him as assailant.
- RTC Decision (September 2, 2016)
- The Regional Trial Court, Branch 94, Quezon City convicted CICL XXX of frustrated homicide, sentencing him to 4 months arresto mayor (min.) to 2 years and 4 months prision correccional (max.) and ordering payment of P18,922.90 actual damages, P30,000 civil indemnity, and P30,000 moral damages.
- CA Decision (September 5, 2017; Resolution January 18, 2018)
- The Court of Appeals affirmed the RTC, finding CICL XXX conspired to inflict fatal injuries on Redoquerio and that the injuries would have caused death absent medical attention; it rejected the minor’s denial as not credible.
Issues:
- Whether the Court of Appeals erred in convicting CICL XXX despite the prosecution’s failure to prove he acted with discernment.
- Whether the Court of Appeals erred in convicting CICL XXX for frustrated homicide without proof of the extent and fatal nature of the injuries sustained by Redoquerio.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)