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    Madali V People - Digest

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    Kai Takishimi
    Raymund and Rodel Madali were charged with homicide for beating and strangling AAA, which caused his death. The RTC found them guilty, and the CA affirmed but dismissed charges against Raymund due to being a minor under the Juvenile Justice Act. The Supreme Court ruled that while Raymund was exempt from criminal liability under the retroactive Juvenile Justice Act, he and Rodel remained civilly liable. It also determined that Rodel acted with discernment but suspended his sentence since he was a child in conflict with the law.

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    Madali V People - Digest

    Uploaded by

    Kai Takishimi
    17 views3 pages
    Raymund and Rodel Madali were charged with homicide for beating and strangling AAA, which caused his death. The RTC found them guilty, and the CA affirmed but dismissed charges against Raymund due to being a minor under the Juvenile Justice Act. The Supreme Court ruled that while Raymund was exempt from criminal liability under the retroactive Juvenile Justice Act, he and Rodel remained civilly liable. It also determined that Rodel acted with discernment but suspended his sentence since he was a child in conflict with the law.

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    Madali v People_Digest

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    Raymund and Rodel Madali were charged with homicide for beating and strangling AAA, which caused his death. The RTC found them guilty, and the CA affirmed but dismissed charges against Raymund due to being a minor under the Juvenile Justice Act. The Supreme Court ruled that while Raymund was exempt from criminal liability under the retroactive Juvenile Justice Act, he and Rodel remained civilly liable. It also determined that Rodel acted with discernment but suspended his sentence since he was a child in conflict with the law.

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    17 views3 pages

    Madali V People - Digest

    Uploaded by

    Kai Takishimi
    Raymund and Rodel Madali were charged with homicide for beating and strangling AAA, which caused his death. The RTC found them guilty, and the CA affirmed but dismissed charges against Raymund due to being a minor under the Juvenile Justice Act. The Supreme Court ruled that while Raymund was exempt from criminal liability under the retroactive Juvenile Justice Act, he and Rodel remained civilly liable. It also determined that Rodel acted with discernment but suspended his sentence since he was a child in conflict with the law.

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    of 3

    RAYMUND MADALI and RODEL MADALI vs.

    PEOPLE OF THE PHILIPPINES

    G.R. Nos. L-33466-67 April 20, 1983

    MAKASIAR, J.:

    FACTS:

    This is the case where Raymund Madali, Rodel Madali and Bernardino “Jojo” Maestro
    was charged of homicide for striking with a coconut frond and "llave inglesa" and
    strangle with a dog chain certain AAA which caused his death.

    At around 11:30 p.m. of 13 April 1999, Jovencio, together with the victim, as well as
    with Rodel, Raymund and Bernardino, went to a place near the Romblon National
    High School. Jovencio’s earlier companion, Michael Manasan, did not go with the
    group, as he had already left a little earlier. As they reached their destination, the
    group ascended the stairs leading to a reservoir near the said school. AAA was
    ahead, followed by Rodel, Raymund, Bernardino and Jovencio. Upon reaching the
    top, Bernardino blindfolded the victim with a handkerchief and told the latter, "Join
    the rugby boys!" The victim responded, "That’s enough!" Bernardino then hit the
    victim thrice, using a green and hard coconut frond. Unable to withstand the
    beatings, the victim hit the ground and was lifted to his feet by Bernardino,
    Raymund and Rodel. With the same coconut frond, Raymund hit the victim on his
    right thigh. Rodel followed by punching the body and the head of the victim with a
    brass knuckle (llave inglesa) wrapped around the former’s right fist. Feeling for his
    cousin, Jovencio shouted "Tama na! Tama na!" Bernardino responded, "Yari na ini,
    ideretso na," (We have come this far, we have to finish it.) The victim’s strength was
    no match to the injuries he received. He passed out. Raymund then tied a
    handkerchief around the victim’s neck, fastened a dog chain to the ends of the said
    handkerchief and, with the aid of Raymund and Rodel, hoisted the victim’s body to
    and hanged it from a nearby tree. Shocked at what was happening, Jovencio just
    watched the whole incident, failing to muster enough courage to help his dying
    cousin.

    RTC found the accused guilty of homicide. CA then affirmed the findings of RTC but
    pursuant to Section 64 of Republic Act No. 9344, otherwise known as the "Juvenile
    Justice and Welfare Act of 2006," which exempts from criminal liability a minor
    fifteen (15) years or below at the time of the commission of the offense, Raymund’s
    case was dismissed.

    While Bernardino applied for probation; the two other accused file a petition for
    certiorari in the Court for the reversal of the decision of CA.

    ISSUE(S):

    Whether or not accused may be convicted of the crime in relation to the retroactive
    effect of RA 9344 or Juvenile Justice and Welfare Act of 2006.

    RULING:

    Page 1 of 3
    Although the crime was committed on 13 April 1999 and Republic Act No. 9344 took
    effect only on 20 May 2006, the said law should be given retroactive effect in favor
    of Raymund who was not shown to be a habitual criminal. This is based on Article 22
    of the Revised Penal Code which provides:
    Retroactive effect of penal laws. — Penal laws shall have a retroactive effect insofar
    as they favor the person guilty of a felony, who is not a habitual criminal, as this
    term is defined in Rule 5 of Article 62 of this Code, although at the time of the
    publication of such laws a final sentence has been pronounced and the convict is
    serving the same.

    While Raymund is exempt from criminal liability, his civil liability is not extinguished
    pursuant to the second paragraph of Section 6, Republic Act No. 9344.

    As to Rodel’s situation, it must be borne in mind that 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

    Discernment is that mental capacity of a minor to fully appreciate the consequences


    of his unlawful act. Such capacity may be known and should be determined by
    taking into consideration all the facts and circumstances afforded by the records in
    each case.

    The Court of Appeals could not have been more accurate when it opined that Rodel
    acted with discernment. Rodel, together with his cohorts, warned Jovencio not to
    reveal their hideous act to anyone; otherwise, they would kill him. Rodel knew,
    therefore, that killing AAA was a condemnable act and should be kept in secrecy. He
    fully appreciated the consequences of his unlawful act. Therefore, Rodel cannot
    claimed exemption from criminal liability.

    However, Rodel can be considered as child in conflict of law; hence, his sentence
    should be suspended in relation to Section 38 of RA 9344.

    DISPOSITIVE:

    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.

    Page 2 of 3
    DOCTRINE

    Although the crime was committed on 13 April 1999 and Republic Act No. 9344 took
    effect only on 20 May 2006, the said law should be given retroactive effect in favor of
    Raymund who was not shown to be a habitual criminal. This is based on Article 22 of
    the Revised Penal Code which provides:

    Retroactive effect of penal laws. — Penal laws shall have a retroactive effect insofar
    as they favor the person guilty of a felony, who is not a habitual criminal, as this
    term is defined in Rule 5 of Article 62 of this Code, although at the time of the
    publication of such laws a final sentence has been pronounced and the convict is
    serving the same.

    Page 3 of 3

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