Case Digest (G.R. No. 46539)
Facts:
The People of the Philippines v. Valentin Doquena, G.R. No. 46539, September 27, 1939, the Supreme Court En Banc, Diaz, J., writing for the Court.The plaintiff-appellee is The People of the Philippines; the defendant-appellant is Valentin Doquena, a minor charged with homicide. Doquena was prosecuted in the Court of First Instance of Pangasinan for stabbing Juan Ragojos in the breast with a knife on November 19, 1938, at Sual, Pangasinan.
At the time of the killing the appellant was 13 years, 9 months and 5 days old. The trial court found the following sequence: Ragojos and Epifanio Rarang were playing volleyball; Doquena caught and threw the ball at Ragojos, who chased and slapped him on the nape. Doquena sought a stone, then asked his cousin Romualdo Cocal for a knife; despite Epifanio’s warning not to lend it, Doquena obtained the knife from Cocal’s pocket. He then approached Ragojos, challenged him, and when Ragojos, unaware of any intent, was stopping the ball with both hands, Doquena stabbed him in the chest.
The trial court concluded that Doquena "acted with discernment" and, applying Article 80 of the Revised Penal Code, as amended by Commonwealth Act No. 99, ordered him committed to the Training School for Boys until he reached majority. The appellant appealed the order to the Supreme Court, contending the court erred in finding discernment and that the case should have been dismissed. The Supreme Court entertained the appeal under the administrative-appeal framewor...(Pro-only)
Issues:
- Did the trial court err in finding that the minor appellant acted with discernment when he stabbed Juan Ragojos?
- If discernment existed, was the disposition — commitment to the Training School for Boys under Article 80 as amended by Commonwealth Act...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)