Case Digest (G.R. No. 264913)
Facts:
People of the Philippines v. Ronald Paradero Aporado, G.R. No. 264913, February 05, 2024, Supreme Court Second Division, Lopez, M., J., writing for the Court.The prosecution (the People of the Philippines) charged Ronald Paradero Aporado (accused‑appellant) with murder by Information alleging that on January 28, 2017 in Bansalan, Davao del Sur, Ronald, armed with a bolo and with treachery, stabbed Amado B. Halasan resulting in instantaneous death. Ronald pleaded not guilty at arraignment.
The factual accounts at trial showed that Ronald, Amado, Jay Amoy, Fritz Montalba and another companion were drinking together when the group teased Ronald about his appearance and Amado challenged him whether he “knew how to kill a person.” Ronald, who admitted feeling humiliated and intoxicated, went home after his sister called him; he returned later, and witnesses testified that he stabbed Amado several times while Amado was seated with his head bowed and asleep. The prosecution further presented testimony that Ronald left, returned with a backpack, and stabbed Amado again while shouting threats. Barangay tanod Janilo Espinosa apprehended Ronald as he walked toward New Visayas and found a knife in his backpack; Ronald allegedly admitted simply that he “just liked to kill” (natripingan lang niya). Ronald himself testified admitting he stabbed Amado five times, explaining he had been mocked, but he denied a second stabbing and gave an account that he attempted to surrender.
The Regional Trial Court (RTC), Branch 21, Digos City, convicted Ronald of murder in a Decision dated January 3, 2019, finding treachery present and sentencing him to reclusion perpetua with damages. Ronald appealed to the Court of Appeals (CA) in CA‑G.R. CR‑HC No. 02268‑MIN; the CA, in a Decision dated November 18, 2020, affirmed the conviction for murder and denied mitigating circumstances and voluntary surrender. The CA denied his motion for reconsideration in a Resolution dated April 20, 2022, reiterating that t...(Subscriber-Only)
Issues:
- Was treachery (alevosia) proven to elevate the killing to murder?
- Are the mitigating circumstances of sufficient provocation, passion and obfuscation, voluntary surrender, or intoxication established in Ronald’s favor?
- What is the appropriate conviction, penalty and modificat...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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