Title
Polo vs. People
Case
G.R. No. 160541
Decision Date
Oct 24, 2008
Ronelo Polo is found guilty of homicide after the Supreme Court rejects his claim of self-defense and clarifies the requirements for mitigating circumstances in the case of Polo v. People.
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Case Digest (G.R. No. 160541)

Facts:

  • Ronelo Polo was charged with the murder of Danilo Balisoro.
  • Prosecution witnesses testified that Polo hacked Balisoro on the head, resulting in his death.
  • Polo claimed self-defense, stating that he witnessed an altercation between Balisoro and his cousin and that Balisoro was about to stab him.
  • Defense witnesses supported Polo's claim of self-defense.
  • The trial court found Polo guilty of homicide but did not appreciate the qualifying circumstances of treachery and evident premeditation.
  • The trial court also did not consider the mitigating circumstance of voluntary surrender.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the decision of the Court of Appeals, finding Polo guilty of homicide.
  • The Court agreed with the lower courts that Polo's claim of self-defense did not have factual basis and that he failed to prove unlawful aggression on the part of Balisoro.
  • The Court also agreed with the Court of Appeals that the mitigating circumstance of sufficient provocation was not present, as there was no showing that Balisoro provoked Polo.
  • The Court further ruled that Polo's surrender was not voluntary, as...(Unlock)

Ratio:

  • The trial court's factual findings, affirmed by the Court of Appeals, are generally conclusive and binding.
  • For self-defense to be valid, there must be unlawful aggression and reasonable necessity of the means employed to prevent or repel it.
  • Polo failed to prove these element...continue reading

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