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
Case Digest (G.R. No. 160541)
Facts:
The case involves Ronelo Polo who was charged with the murder of Danilo Balisoro on February 27, 1995. During the trial, prosecution witnesses testified that Polo hacked Balisoro on the head after a short conversation. Balisoro was brought to the hospital but later died due to his injuries. Polo admitted to hacking Balisoro but claimed it was in self-defense. He stated that he witnessed an altercation between Balisoro and his cousin and was trying to help his cousin when Balisoro attacked him. Polo said he escaped and ran to his house where he grabbed a balisong and used it to strike Balisoro. Polo then fled the scene and surrendered to a policeman. Defense witnesses corroborated Polo's claim of self-defense.
Issue:
The main issue in this case is whether Polo acted in self-defense and whether the mitigating circumstances of voluntary surrender and sufficient provocation should be appreciated.
Ruling:
The Supreme Court ruled that the Court of Appeals was correct in not appreciating the mitigating circumstance of sufficient provocation. There was no showing that Balisoro provoked Polo, and even if there was provocation, it was not enough...