Case Digest (G.R. No. 11979)
Facts:
The United States v. Maximo Maralit, G.R. No. L-11979, January 25, 1917, the Supreme Court, Moreland, J., writing for the Court. The plaintiff-appellee was the United States and the defendant-appellant was Maximo Maralit.
Maralit was tried, convicted of homicide by the trial court and sentenced to five (5) years prision correccional, the accessories provided by law, indemnity to the heirs of the deceased in the sum of P1,000, and costs. The prosecution presented two eyewitnesses who testified that they and the deceased, Florentino Luistro, were walking in single file each carrying a bundle of zacate on the head when they met Maralit and a companion; after a brief scuffle, Maralit ran at Luistro and stabbed him in the left side with a knife, then fled. Luistro later died of the wound.
Maralit and a defense witness offered a different account: after some sharp words Luistro allegedly attacked Maralit with a club, and Maralit, acting in self-defense, used his dagger. The trial court credited the prosecution witnesses and found Maralit guilty.
Counsel for appellant challenged the trial court’s factual findings and argued that, because Maralit was under fifteen years of age, the prosecution failed to prove that he acted “with discernment” within the meaning of paragraph 3 of Article 8 of the Penal Code; counsel therefore urged acquittal or relief. The trial court had expressly found that Maralit acted with discernment. The case was brought to the Supreme Court on appeal from the conviction. The Supreme Court reviewed the evidence, upheld the trial court’s findings as supp...(Subscriber-Only)
Issues:
- Should the trial court’s findings of fact, including credibility determinations, be reversed?
- Did the defendant, being over nine and under fifteen years of age, act “with discernment” so as to be criminally liable under Article 8, paragraph 3 of the Penal Code?
- Was the penalty imposed proper under Article 85 of the Penal Code for a minor found t...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)