Case Summary (G.R. No. 116123)
Petitioner and Respondent
Petitioner: Ronnie Caluag
Respondent: People of the Philippines
Key Dates
March 19, 2000 – Alleged mauling and gun-poking incidents
May 18 & 23, 2000 – Filing of Informations (Criminal Cases Nos. 47381 & 47358)
January 28, 2004 – MeTC Joint Decision convicting Caluag and Sentillas
August 3, 2004 – RTC affirmation
December 9, 2005 – CA Decision affirming RTC
March 4, 2009 – Supreme Court resolution
Applicable Law
1987 Philippine Constitution
Revised Penal Code:
• Article 282 (grave threats)
• Article 283 (light threats)
• Article 285 (other light threats)
Facts of the Case
- Criminal Case No. 47381 charged Caluag and Sentillas with slight physical injuries on Nestor Denido, who required less than nine days’ medical care.
- Criminal Case No. 47358 charged Caluag with grave threats by pointing a gun at Julia Denido’s forehead and uttering, “Saan ka pupunta, gusto mo ito?”
Procedural History
– MeTC found both accused guilty of slight physical injuries and Caluag guilty of grave threats.
– RTC and CA affirmed the convictions, ruling that the positive, straightforward testimonies of Nestor and Julia outweighed the accused’s denials.
– Caluag filed a petition for certiorari under Rule 45, challenging factual findings and credibility assessments.
Issue on Review
Whether the evidence sufficiently established Caluag’s guilt for slight physical injuries and grave threats beyond reasonable doubt.
Court’s Analysis on Witness Credibility
– Rule 45 limits Supreme Court review to errors of law; factual findings of lower courts are final when unanimously affirmed.
– MeTC, RTC, and CA uniformly credited the Denidos’ testimonies as coherent with the natural course of events.
– The sole defense witness, Pablo Barrameda Jr., offered a version contradicted by the complainants’ positive declarations.
– Immediate barangay reporting by Julia supported the occurrence of the gun-poking incident.
Legal Classification of Threats
– Article 282 covers threats to commit a crime; punishable by arresto mayor and fine when no condition is imposed.
– Articles 283 and 285 address non-criminal threats with or without conditions.
– Pointing a gun at Julia’s forehead signaled an uncondi
Case Syllabus (G.R. No. 116123)
Procedural History
- On May 18 and 23, 2000, two Informations were filed in the Metropolitan Trial Court (MeTC) of Las Piñas City as Criminal Cases Nos. 47381 and 47358 charging Ronnie Caluag (and co-accused Jesus Sentillas in No. 47381).
- The MeTC rendered a Joint Decision on January 28, 2004, finding both accused guilty of slight physical injuries (No. 47381) and Caluag guilty of grave threats (No. 47358), and ordering the dismissal of a duplicate case.
- On August 3, 2004, the Regional Trial Court (RTC), Branch 198, Las Piñas City, affirmed the MeTC decision in Criminal Case No. 04-0183-84.
- The Court of Appeals, Third Division, in CA-G.R. CR No. 28707, issued its Decision on December 9, 2005, and denied reconsideration in its Resolution dated February 15, 2006, affirming the RTC in toto.
- Caluag filed a petition for review on certiorari under Rule 45 before the Supreme Court, which promulgated judgment on March 4, 2009.
Facts of the Case
- On March 19, 2000, at around 4:00 PM in Las Piñas City, Nestor Purcel Denido learned that two of his drinking-party guests had been mauled.
- He found Ronnie Caluag and Jesus Sentillas drinking at a store owned by Sentillas’s son and inquired into the incident; Caluag allegedly boxed Denido without warning and, together with Sentillas, overpowered him.
- Julia Lavial Denido witnessed the mauling, attempted to pacify the assailants, then accompanied her husband home and later went to report the assault to barangay authorities around 7:30 PM.
- En route, Caluag purportedly intercepted Julia in an alley, pointed a firearm at her forehead, and uttered “Saan ka pupunta, gusto mo ito?” threatening serious harm.
Charged Offenses
- Criminal Case No. 47381: Slight Physical Injuries (Article 263, paragraph 1, RPC) – physical injuries requiring medical attendance for less than nine days.
- Criminal Case No. 47358: Grave Threats (Article 282, paragraph 2, RPC) – threat to inflict harm amounting to a crime, exhibited by pointing a gun without condition.
Complainants’ Version
- Nestor Denido: Asserted that Caluag and Sentillas conspired to maul him, causing injuries that incapacitated him for several days.
- Julia Denido: Corroborate