Case Digest GR No 180380
Case Digest GR No 180380
Province, Philippines, within the jurisdiction of its Honorable Court, with intent to murder, conspired to
cause the suicide of a friend and ally. Defendant said he planned Helping each other, with treason and
obvious intentions, knowingly, illegally, criminally attacked, attacked, attacked, beaten with coconut
leaves and "llave inglesa", strangled with dog chains AAA fatally wounded the latter. different parts of
his body that caused his untimely death. At the May 31, 2000 indictment, the three defendants pleaded
not guilty with the support of their attorneys. Evidence presented by the prosecution shows that on
April 13, 1999, around 5:30 pm, the BBB sold goods aboard a vessel docked at Romblon's pier, which
was constantly being sold by his 15-year-old son. AAA was supported and on board the ship to deliver
the goods. AAA was there to help his mother with Jovencio and Raymond. After a while, Raymond and
AAA left the ship. Jovencio stayed a little longer. Around 9 p.m. On the same day, Jovencio and another
friend named Michael Manathan were sitting next to the Rizal Monument in Poblacion, Romblon,
between the Roman Catholic Church and Lover's Inn. Raymund , Rodel, Bernardino, and the victim, AAA,
had just left Jovencio. After wandering around, the group climbed the steps to a reservoir right next to
Romblon National High School. Victim AAA got on first. Behind him were Rodel, Raymond, Bernardino
and the witness Jovencio. As soon as they reached the reservoir, Bernardino AAA was blindfolded with
Raymond's handkerchief. Bernardino immediately muttered, "Let's join the boys' rugby team." AAA
replied, "That's enough." Bernardino then hit his AAA with a fresh, hard coconut leaf his third. AAA lost
their balance and were forced to rise by Raymund, Rodel and Bernardino. On Raymund's turn, he hit the
back of the thigh with the same coconut leaf AAA. AAA wobbled. Before he could recover, he received
blows to his head and body from a brass-knuckle-wearing Rodell, and the penalty proved too much
when AAA was knocked unconscious. Unsatisfied, Raymond puts the handkerchief around AAA's neck
and ties the end to the dog's leash. Using a device, the three assailants pulled the corpse up a tree.
Stunned to see his cousin being abused, Jovencio could only muster a weak voice to say "enough is
enough" each time AAA was painfully beaten. "We're all here, let's move on," Bernardino said. I warned
you not to reveal it to anyone. Three days later, a certain Eugenio Murchanto reported to police
authorities that a dead body had been found in his barangay ZZZ near Romblon National High School.
When police went to the scene, they found the body hanging from a tree with maggots crawling
everywhere, a handkerchief around his neck, and a dog chain attached to the handkerchief. Rugby
inhalers, empty gin bottles and coconut leaves were also found in the area.
Persuaded by the prosecution's opinion, RTC convicted her three defendants. He was only convicted of
manslaughter because the prosecution failed to prove conclusive circumstances and clear intent for
treason. RTC pointed out that the incident was a kind of initiation and that the victim voluntarily
accompanied the perpetrator and was not completely unaware of the beating. RTC also granted minor
privilege relief status in favor of three defendants.
Issue: The petitioners RAYMUND MADALI and RODEL MADALI are exempted from criminal liabilities
since they were minors at the time they committed the crime. Although they are not exempted from
civil liabilities.
As to the criminal liability, Raymond is exempt. As correctly ruled by the Court of Appeals, Raymund,
who was only 14 years of age at the time he committed the crime, should be exempt from criminal
liability and should be released to the custody of his parents or guardian pursuant to Sections 6 and 20
of Republic Act No. 9344, to wit:
SEC. 6. Minimum Age of Criminal Responsibility. — A child fifteen (15) years of age or under at the time
of the commission of the offense shall be exempt from criminal liability. However, the child shall be
subjected to an intervention program pursuant to Section 20 of this Act.
SEC. 20. Children Below the Age of Criminal Responsibility. — If it has been determined that the child
taken into custody is fifteen (15) years old or below, the authority which will have an initial contact with
the child has the duty to immediately release the child to the custody of his/her parents or guardian, or
in the absence thereof, the child's nearest relative. Said authority shall give notice to the local social
welfare and development officer who will determine the appropriate programs in consultation with the
child and to the person having custody over the child. If the parents, guardians or nearest relatives
cannot be located, or if they refuse to take custody, the child may be released to any of the following: a
duly registered nongovernmental or religious organization; a barangay official or a member of the
Barangay Council for the Protection of Children (BCPC); a local social welfare and development officer;
or, when and where appropriate, the DSWD. If the child referred to herein has been found by the Local
Social Welfare and Development Office to be abandoned, neglected or abused by his parents, or in the
event that the parents will not comply with the prevention program, the proper petition for involuntary
commitment shall be filed by the DSWD or the Local Social Welfare and Development Office pursuant to
Presidential Decree No. 603, otherwise known as "The Child and Youth Welfare Code."
As for Rodel Madali, he was 16 years old at the time of the commission of the crime, a determination of
whether he acted with or without discernment is necessary pursuant to Section 6 of Republic Act No.
9344:
A child above fifteen (15) years but below eighteen (18) years of age shall likewise be exempt from
criminal liability and be subjected to an intervention program, unless he/she has acted with
discernment, in which case, such child shall be subjected to the appropriate proceedings in accordance
with this Act.
The sentence to be imposed against Rodel should be suspended pursuant to Section 38 of Republic Act
No. 9344, which states:
SEC. 38. Automatic Suspension of Sentence. – Once the child who is under eighteen (18) years of age at
the time of the commission of the offense is found guilty of the offense charged, the court shall
determine and ascertain any civil liability which may have resulted from the offense committed.
However, instead of pronouncing the judgment of conviction, the court shall place the child in conflict
with the law under suspended sentence, without need of application. Provided, however, That
suspension of sentence shall still be applied even if the juvenile is already eighteen (18) years of age or
more at the time of the pronouncement of his/her guilt.
Ruling: WHEREFORE, the petition is DENIED. The Decision of the Court of Appeals dated 29
August 2007 in CA-G.R. No. 27757, exempting Raymund Madali from criminal liability is hereby
AFFIRMED. With respect to Rodel Madali, being a child in conflict with the law, this Court suspends
the pronouncement of his sentence and REMANDS his case to the court a quo for further
proceedings in accordance with Section 38 of Republic Act No. 9344. However, with respect to the
civil liabilities, Rodel Madali and Raymund Madali are solidarily liable to pay the heirs of the victim
the amount of ₱50,000.00 as civil indemnity, ₱50,000.00 as moral damages and ₱25,000.00 as
temperate damages.