G.R. No. 46539; September 27, 1939
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VALENTIN DOQUEÑA, defendant-appellant.

FACTS

The accused-appellant, Valentin Doqueña, a minor aged 13 years, 9 months, and 5 days, was prosecuted for homicide for stabbing and killing Juan Ragojos on November 19, 1938, in Sual, Pangasinan. The incident began when the accused, while playing volleyball, tossed the ball at the victim, hitting him. The victim chased and slapped the accused, who then retaliated by asking for a knife from his cousin. After obtaining the knife, the accused challenged the victim and then stabbed him in the chest while the victim was unprepared and playing.

ISSUE

Whether the accused, a minor over nine but under fifteen years of age, acted with discernment in committing the homicide, thereby making him criminally liable under Article 80 of the Revised Penal Code.

RULING

Yes. The Supreme Court affirmed the trial court’s order, holding that the accused acted with discernment. The Court ruled that discernment refers to the mental capacity to understand the difference between right and wrong, not to premeditation or the time for reflection. The trial court correctly determined discernment based on the accused’s proven status as a bright 7th-grade student, a captain in the cadet corps, and his comportment before, during, and after the act, including during trial. Thus, the accused was properly committed to the Training School for Boys until reaching majority.

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