G.R. No.: L-11979
Title: The United States vs. Maximo Maralit

FACTS:
The defendant-appellant, Maximo Maralit, was convicted of homicide for stabbing and killing Florentino Luistro. The prosecution presented two witnesses who testified that they, along with the deceased, were walking in single file carrying bundles of zacate when they met Maralit and a companion. After passing each other, they heard a noise, turned around, and saw Maralit and Luistro fighting with their fists. After separating, Luistro stooped to pick up his dropped bundle, at which point Maralit quickly approached and stabbed him in the left side with a knife. Maralit and his companion then fled. Luistro died a few days later from the wound.

The defense presented a different version, claiming that Luistro initiated the attack by striking Maralit with a club after an exchange of words, and that Maralit used his dagger in self-defense. The trial court rejected the defense’s account and found the prosecution’s witnesses credible.

At the time of the crime, Maralit was less than 15 years old, while the deceased was less than 16. The trial court found that Maralit acted with discernment, a necessary finding for criminal liability under Article 8 of the Penal Code for minors between 9 and 15 years of age.

ISSUE:
1. Whether the trial court erred in its factual findings regarding the incident.
2. Whether the prosecution proved that Maralit acted with discernment, given his age.
3. Whether the penalty imposed was correct.

RULING:
1. On the factual findings: The Supreme Court upheld the trial court’s findings of fact, concluding that there was no sufficient reason to reverse the lower court’s assessment of the witnesses’ credibility. The evidence supported the prosecution’s version that Maralit unlawfully stabbed Luistro.

2. On discernment: The Court ruled that the trial court properly found that Maralit acted with discernment. While no witness directly testified to this fact, discernment could be inferred from the evidence as a whole, including the circumstances of the crime and Maralit’s appearance and testimony in court. The law does not require direct affirmative evidence; a reasonable inference from the record is sufficient.

3. On the penalty: The Court modified the penalty. Under Article 85 of the Penal Code, a minor under 15 but over 9 years of age who acts with discernment is subject to a penalty lower by at least two degrees than that prescribed for the offense. The trial court imposed five years of prision correccional, but the correct penalty should be two years of prision correccional.

Dispositive: The judgment of conviction was AFFIRMED, but the penalty was MODIFIED to two years of prision correccional, with the corresponding accessories, indemnity to the heirs of the deceased, and costs.