Case Digest (G.R. No. 75256) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In John Philip Guevarra v. Hon. Ignacio Almodovar, petitioner John Philip Guevarra, then an eleven-year-old boy, was playing with four companions, including Teodorico Pablo Almine Jr., in the backyard of a Legaspi City residence on the morning of October 29, 1984. They used an air rifle borrowed from a neighbor to target-shoot a bottle cap placed some fifteen to twenty meters away. Tragically, one pellet struck Teodorico on the left collarbone, causing injuries that resulted in his death. Following a preliminary investigation, the fiscal exculpated John Philip due to his age and the accidental nature of the incident. The victim’s parents appealed, prompting the Ministry of Justice to direct the fiscal to file a homicide by reckless imprudence charge against petitioner. An information was thus lodged on October 9, 1985, alleging that John Philip, a minor “over nine years but below fifteen years of age and acting with discernment,” willfully and recklessly fired the air rifle, cau Case Digest (G.R. No. 75256) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Factual Background
- On October 29, 1984, petitioner John Philip Guevarra, then 11 years old, and four companions played target-shooting with a borrowed .22-caliber air rifle in his backyard in Legazpi City.
- A pellet struck Teodorico Pablo Almine Jr. on the left collarbone, causing fatal injuries and his immediate death.
- Procedural History
- The examining fiscal exculpated the petitioner due to his age and the apparent accidental nature of the incident.
- The victim’s parents appealed to the Ministry of Justice, which directed the filing of an information for homicide through reckless imprudence under Article 365 of the Revised Penal Code.
- The October 9, 1985 information alleged petitioner “over 9 years but below 15 years of age and acting with discernment” willfully and recklessly operated the air rifle, causing death.
- On October 25, 1985, petitioner moved to quash the information on three grounds; by Order of April 4, 1986, the trial court denied quashal as to grounds I and III and deferred ruling on ground II until trial.
- On July 26, 1986, petitioner filed a petition for certiorari with the Supreme Court, raising:
- Whether an eleven-year-old can be charged with homicide through reckless imprudence.
- Whether the court had jurisdiction despite no barangay conciliation under P.D. 1508.
Issues:
- Can an eleven-year-old minor be charged with homicide through reckless imprudence under the RPC, given the exemption for minors between nine and fifteen years (“discernment”)?
- Does the trial court have jurisdiction over the case despite the absence of prior barangay conciliation under P.D. 1508, Section 2(3)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)