G.R. No. 171511 March 4, 2009
Ronnie Caluag, Petitioner, vs. People of the Philippines, Respondent.
FACTS
Two separate Informations were filed against petitioner Ronnie Caluag and Jesus Sentillas. In Criminal Case No. 47381, they were charged with slight physical injuries for allegedly mauling Nestor Purcel Denido on March 19, 2000. In Criminal Case No. 47358, Caluag was charged with grave threats for allegedly poking a gun at the forehead of Julia Lavial Denido, Nestor’s wife, on the same day and uttering, “Saan ka pupunta gusto mo ito?” The prosecution’s version, based on the testimonies of spouses Nestor and Julia Denido, states that around 4:00 p.m., Caluag, without warning, boxed Nestor after Nestor inquired about a mauling incident; Caluag and Sentillas then mauled him. Later, around 7:30 p.m., as Julia was on her way to the barangay hall to report the mauling, Caluag blocked her way, poked a gun at her forehead, and uttered the threatening words. The defense’s version, presented by Caluag, Sentillas, and witness Pablo Barrameda, Jr., claims that around 6:00 p.m., a drunk and unruly Nestor blocked Caluag’s way, persisted in questioning him, and then boxed him first; Caluag retaliated in self-defense, and Sentillas did not box Nestor. Caluag denied poking a gun at Julia. The Metropolitan Trial Court (MeTC) found Caluag and Sentillas guilty of slight physical injuries and Caluag guilty of grave threats, a decision affirmed by the Regional Trial Court (RTC) and the Court of Appeals.
ISSUE
Was there sufficient evidence to sustain petitioner’s conviction of slight physical injuries and of grave threats?
RULING
Yes, the Supreme Court sustained the conviction. The petition raised questions of fact, which are generally not reviewable under Rule 45, as findings of fact by the trial court, when affirmed by the Court of Appeals, are binding and conclusive. The Court found no ground to depart from this rule, as the findings of the MeTC, RTC, and Court of Appeals completely coincided. The lower courts rightly gave credence to the positive, straightforward, and natural testimonies of the prosecution witnesses over the denials of the defense. Regarding the crime of threats, the Court held that Caluag’s act of poking a gun at Julia’s forehead and uttering the words constituted grave threats under Article 282, paragraph 2 of the Revised Penal Code, as the threat to kill or shoot amounts to a crime and was not subject to a condition. The inapplicability of Article 285, paragraph 1 (other light threats) was clarified, as that article presupposes the threatened wrong would not constitute a crime. The petition was denied for lack of merit, and the assailed Decision and Resolution of the Court of Appeals were affirmed.