G.R. No. 238798 , March 14, 2023
CICL XXX, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner CICL XXX, a minor aged 17 at the time, was charged with Homicide for the death of AAA. The prosecution established that on October 28, 2003, AAA was found bloodied outside his home. He told his mother, BBB, that CICL XXX and a companion were inside his house and that CICL XXX struck his eyes when he confronted them. AAA had previously testified against CICL XXX in a barangay hearing on October 27, 2003. AAA suffered severe brain injuries, was hospitalized, and eventually died on November 26, 2008. The cause of death was linked to blunt trauma to the head. CICL XXX denied the allegations, claiming he was drinking with friends elsewhere during the incident. The Regional Trial Court (RTC) convicted CICL XXX of Homicide. The Court of Appeals (CA) affirmed the conviction but modified the penalty, applying the privileged mitigating circumstance of minority under Republic Act No. 9344 (Juvenile Justice and Welfare Act of 2006).

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of CICL XXX for Homicide and properly applied the laws and rules concerning his minority as a mitigating circumstance.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Decision of the Court of Appeals with modifications. The Court held that the prosecution proved CICL XXX’s guilt beyond reasonable doubt for Homicide. The dying declaration of AAA to his mother was admissible as part of the res gestae. The Court ruled that CICL XXX is entitled to the privileged mitigating circumstance of minority. Applying Republic Act No. 9344 , as amended, and the 2019 Supreme Court Revised Rule on Children in Conflict with the Law, the penalty was adjusted accordingly. The Court imposed an indeterminate sentence and ordered CICL XXX to pay damages to the heirs of AAA. The case was remanded to the trial court for appropriate action under Section 51 of R.A. No. 9344 .