G.R. No. 116635 - Nool vs. Court of Appeals

The defendant, Maximo Maralit, was charged and subsequently convicted of homicide for stabbing Florentino Luistro in the left side with a knife.
As a result of his conviction, the defendant was sentenced to five (5) years of prision correccional, ordered to pay accessory costs, and mandated to indemnify the heirs of the deceased in the sum of P1,000.
The case involved conflicting narratives regarding the events that led to the stabbing.

They testified that while walking in single file each carrying a bundle of zacate, they encountered the defendant accompanied by a companion and the deceased.
As they passed each other, they heard a sound resembling the dropping of a bundle of zacate, followed by a physical altercation in which Florentino Luistro and the defendant engaged in a fistfight.
The witnesses observed that after Florentino stooped to pick up his bundle, the defendant ran quickly towards him and stabbed him in the left side with a knife.

The witnesses stated that after the stabbing, the defendant and his companion immediately fled the scene, while both Florentino and the witnesses returned to their respective homes.
The death of Florentino Luistro occurred a few days later as a direct result of the wound received from the stabbing.

It was asserted that following a heated exchange involving sharp words, Florentino Luistro initiated an attack on the defendant using a club.
In response, the defendant claimed to have acted in self-defense by using his dagger, which resulted in Florentino’s fatal injury.

Despite the defense’s version, the trial court opted for the testimony of the prosecution’s witnesses, finding it more credible and supported by the evidence as a whole.

The defendant was less than 15 years of age at the time of the offense, making him a minor under Philippine law.
Paragraph 3 of Article 8 of the Penal Code provides that a person aged over 9 and under 15 is generally exempt from criminal liability unless it is found that he acted with discernment.
The trial court, after a careful review of the circumstances and the demeanor of the accused in court, determined that the defendant possessed sufficient intelligence and judgment to be aware that his act was wrongful and likely to cause death, thus establishing that he acted with discernment.

Whether the trial court’s findings of fact, particularly regarding the events of the stabbing and the credibility of the testimonies presented, were sufficiently supported by evidence to withstand reversal.
Whether the evidence on record adequately establishes that the defendant, despite his minority status, acted with discernment at the time of the crime.
Whether the imposition of a five (5) year sentence was appropriate, considering the statutory requirement under Article 85 of the Penal Code for minors found to have acted with discernment to receive a penalty reduced by at least two degrees from that prescribed for the offense.