Title
People vs. Rodil
Case
G.R. No. L-35156
Decision Date
Nov 20, 1981
Rodil stabbed PC Lt. Masana during a confrontation over an unlicensed gun, claiming self-defense. Court ruled homicide, applying aggravating circumstances, modifying penalty.

Case Digest (G.R. No. 19982)
Expanded Legal Reasoning Model

Facts:

  • Identity of Parties and Crime Charged
    • Floro Rodil (accused-appellant) was charged with the murder of Lt. Guillermo Masana of the Philippine Constabulary.
    • The crime was alleged to have occurred on April 24, 1971, in Indang, Cavite, involving stabbing with a double-bladed dagger.
  • Incident Details
    • Around 1:00 PM, Lt. Masana and companions were having lunch inside a restaurant in Indang when they noticed Rodil outside.
    • Lt. Masana, in civilian clothes and accompanied by PC soldier Virgilio Fidel, approached Rodil and asked about a gun carried by Rodil.
    • Rodil attempted to draw his gun, which was seized by Virgilio Fidel and handed to Lt. Masana.
    • Lt. Masana asked Rodil to come inside the restaurant and they sat at a table about 1.5 meters from the companions’ table.
    • Lt. Masana wrote a receipt for the gun, asking Rodil to countersign, which Rodil refused.
    • When Lt. Masana was about to stand, Rodil pulled a double-bladed dagger and stabbed Lt. Masana several times in the chest and abdomen.
    • The companions and the Chief of Police, Primo Panaligan, intervened; the Chief of Police disarmed Rodil and took him to the municipal building.
    • Lt. Masana was brought to the V. Luna Hospital where he died several hours later from the stab wounds.
  • Medical Evidence
    • Dr. Felicisimo del Rosario conducted an autopsy.
    • Findings included multiple stab wounds to the chest and abdomen causing perforations of stomach, gastric vessels, liver, diaphragm, and lung.
    • Cause of death was cardio-respiratory arrest due to severe shock and intrathoracic hemorrhage from the wounds.
  • Accused’s Defense (Self-Defense Claim)
    • Rodil and his wife went to the restaurant; Rodil was approached by Lt. Masana who questioned his identity and Anti-Smuggling Unit membership.
    • Lt. Masana accused Rodil’s ID card of being fake and tried to confiscate it, provoking the accused.
    • A physical altercation ensued where Lt. Masana allegedly hit Rodil twice on the head with the butt of his gun.
    • Rodil claimed he stabbed Masana in self-defense after parrying the third blow.
    • Rodil went toward the municipal building intending to surrender but was stopped by the Chief of Police.
    • He was treated for his head injuries and detained for two days before transfer to PC headquarters.
    • Self-defense was first claimed only after more than two months during preliminary investigation.
  • Trial Court Findings and Sentencing
    • The Circuit Criminal Court of Pasig, Rizal found Rodil guilty beyond reasonable doubt of murder.
    • Sentence: death penalty, indemnity of P12,000 to heirs, moral damages of P10,000, exemplary damages of P10,000, and costs.

Issues:

  • Whether the accused successfully proved the claim of self-defense.
  • Whether the crime charged was murder or homicide, or murder/homicide complexed with assault upon an agent of authority.
  • Whether the aggravating circumstances of treachery (alevosia), contempt or insult against public authority, and disregard of rank are present and applicable.
  • Whether the accused had knowledge that the victim was an agent of a person in authority at the time of the stabbing, and the legal effect of such knowledge or lack thereof.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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