Title
Caluag vs. People
Case
G.R. No. 171511
Decision Date
Mar 4, 2009
Caluag convicted for mauling Nestor Denido and threatening Julia with a gun; SC upheld lower courts' rulings based on credible testimonies and sufficient evidence.

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

  1. Criminal Case No. 47381 charged Caluag and Sentillas with slight physical injuries on Nestor Denido, who required less than nine days’ medical care.
  2. 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

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