Michael Angelo B.

Laurio

Law 1 block A

Case Digest
Criminal Law

People vs Maningding
G.R. No. 195665
14 September 2011

Facts: David Maningding was accused and subsequently found guilty by the Regional
Trial Court of Dagupan City for the murder of Marlon Muyalde on the evening of
September 13, 2006 at Brgy. Anolid, Mangaldan, Pangasinan. During the trial,
the prosecution presented as evidence the testimonies of Aladino Jorge, the
owner of the sari-sari store where the alleged crime was committed in its vicinity,
Dr. Virgilio De Guzman, the physician who conducted the autopsy of the victim,
Rommel Muyalde, the brother of the victim, and Gloria Muyalde, the wife of the
victim. All four individuals testified in support of the prosecution’s argument that
Maningding wilfully stabbed and killed the victim, Muyalde and that the latter’s
death has left his family in financial ruin. On the side of the defense, Maningding
claimed, as the only one who testified, that he only acted in self-defense; an
argument which the RTC did not give great weight and therefore led to his
conviction. Not agreeing with the findings of the lower court, accused-appellant
Maningding later on appealed his conviction at the Court of Appeals. The
appellate court affirmed the findings and judgment of the Regional Trial Court
and further held that it was not in any way persuaded by the appeal of the
accused and his claim of self-defense. The Court of Appeals emphasized that the
element of unlawful aggression is wanting in the present case. As a last resort,
Maningding appealed his case at the Supreme Court.

Issue: Whether the Regional Trial Court erred in convicting accused-appellant

Maningding of the crime charged since he maintained that the stabbing of the
victim was justified by self-defense.

Ruling: No, the Regional Trial Court’s judgment, as well as the affirmation of the Court
of Appeals, was correct.
In the case at bar, the Supreme Court ruled that the conviction of accused-
appellant should be sustained for (1) the factual determination of the RTC should
be afforded full faith and credit and (2) self-defense, as claimed by Maningding,
does not exist in the present case.

In the first reason, it was noted by the Supreme Court that that the factual
determination of the RTC should not be disturbed unless there is a showing of
misinterpretation of material facts or that it is tainted with grave abuse of
discretion. In the present case, in giving weight to the prosecution’s testimonies,
there is not a slight indication that the RTC acted with grave abuse of discretion,
or that it overlooked any material fact. In fact, no allegation to that effect ever
came from the defense. There is therefore no reason to disturb the findings of
fact made by the RTC and its assessment of the credibility of the witnesses.

In the second reason, the Supreme Court reiterated a settled rule that when an
accused claims the justifying circumstance of self-defense, an accused admits
the commission of the act of killing. The burden of evidence, therefore, shifts to
the accused’s side in clearly and convincingly proving that the elements of self-
defense exist that could justify the accused’s act. In this case, considering that at
the outset, accused-appellant has already maintained a claim of self-defense, the
burden of evidence rests upon him in proving his act of stabbing as justifiable
under the circumstances. Furthermore, the Supreme Court stated that the
records would show that accused-appellant was clearly not able to establish the
requisites of self-defense as enumerated in paragraph 1, Article 11 of the
Revised Penal Code. Worse, his sole evidence––his own testimony––was found
by the RTC to be so weak and devoid of any credibility as against those
presented by the prosecution. From the facts of the present case, the RTC gave
credence and weight to the evidence presented by the prosecution, whose
testimonies rule out accused-appellant’s claim of self-defense.
 People vs. Oanis et.al.
G.R. No. L-47722
27 July 1943

Facts: Anselmo Balagtas was a notorious criminal who managed to escape and flee
from Manila to the provinces. Receiving information to the effect that he was
staying with one Irene Requinea in Cabanatuan, Nueva Ecija, the Office of the
Constabulary in Manila ordered the Provincial Inspector in Cabanatuan by
telegram dispatched on December 25, 1938, to get Balagtas "dead or alive".
Among those assigned to the task of carrying out the said order, were Antonio Z.
Oanis, Chief of Police of Cabanatuan, and Alberto Galanta, a Constabulary
corporal, to whom the telegram received by the Provincial Inspector and a
newspaper picture of Balagtas were shown. Oanis, Galanta and a Constabulary
private, after being told by the Provincial Inspector to gather information about
Balagtas, "to arrest him and, if overpowered, to follow the instructions contained
in the telegram," proceeded to the place where the house of Irene was located.
Upon arrival at the house, Oanis approached Brigida Mallari, who was then
gathering banana stalks in the yard, and asked where the room of Irene was.
After Mallari had pointed out the room, she was asked by Oanis to tell where
Irene's paramour, Balagtas, was, whereupon Mallari answered that he was
sleeping with Irene. Upon reaching the room indicated, Oanis and Galanta, after
the former had shouted "Stand up, if you are Balagtas," started shooting the man
who was found by them lying down beside a woman. The man was thereby
killed, but Balagtas was still alive, for it turned out that the person shot by Oanis
and Galanta was one Serapio Tecson, an innocent civilian. These facts were the
ones that were included in the testimony of Irene Requinea during the trial. On
the part of the accused-appellants, they each presented a slightly different
version of what transpired, both of which were rejected by the trial court. The
Court of First Instance held that both the accused-appellants’ testimonies were
certainly incredible not only because they were vitiated by a natural urge to
exculpate themselves of the crime, but also because they were materially
contradictory. With this being said, the lower court eventually, found both the
accused-appellants guilty of homicide through reckless imprudence. Not
agreeing to the sentence, Oanis and Galanta appealed their case to the
Supreme Court.

Issue: Whether both accused-appellants had no criminal liability due to “mistake of fact.”

Ruling: No, both the accused-appellants had criminal liability and cannot invoke mistake
of fact.

It was held by the Supreme Court that unlike in the case of US vs. Ah Chong,
accused-appellants, in the case at bar, found no circumstances whatsoever
which would press them to immediate action. The person in the room being then
asleep, appellants had ample time and opportunity to ascertain his identity
without hazard to themselves, and could even conduct a bloodless arrest if any
reasonable effort to that end had been made, as the victim was unarmed,
according to Irene Requinea. This, indeed, is the only legitimate course of action
for appellants to follow even if the victim was really Balagtas, as they were
instructed not to kill Balagtas at sight but to arrest him, and to get him dead or
alive only if resistance or aggression is offered by him. Furthermore, it is
suggested that a notorious criminal "must be taken by storm" without regard to
his right to life which he has by such notoriety already forfeited. The Court may
approve of this standard of official conduct where the criminal offers resistance or
does something which places his captors in danger of imminent attack.
Otherwise the Court cannot see how, as in the present case, the mere fact of
notoriety can make the life of a criminal a mere trifle in the hands of the officers
of the law. Notoriety rightly supplies a basis for redoubled official alertness and
vigilance; it never can justify precipitate action at the cost of human life. Where,
as here, the precipitate action of the appellants has cost an innocent life and
there exists no circumstances whatsoever to warrant action of such character in
the mind of a reasonably prudent man, condemnation — not condonation —
should be the rule.