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RONNIE CALUAG v. PEOPLE

FACTS:

The case involves the review of the decision of the Court of Appeals affirming the decision of the Regional Trial Court (RTC) and Metropolitan Trial Court (MeTC) finding the petitioner Ronnie Caluag and Jesus Sentillas guilty of slight physical injuries and Ronnie Caluag guilty of grave threats. The two separate Informations filed against Caluag and Sentillas charged them with slight physical injuries and grave threats.

The prosecution presented the private complainants, Nestor and Julia Denido, who testified that they were attacked and assaulted by Caluag and Sentillas. On the other hand, the defense presented Caluag, Sentillas, and a witness who testified that it was Nestor who instigated the incident.

The MeTC found Caluag and Sentillas guilty, relying on the positive testimonies of Nestor and Julia, and the RTC affirmed this decision. The Court of Appeals also affirmed the decision of the RTC, noting that the testimonies of Nestor and Julia were in accord with the natural course of things.

Dissatisfied, petitioner appealed to the Supreme Court.

ISSUES:

  1. Was there sufficient evidence to sustain petitioner's conviction of slight physical injuries and of grave threats?

  2. Did the lower courts err in giving credence to the testimonies of Nestor and Julia instead of the witness presented by the petitioner?

  3. Whether the petitioner is guilty of grave threats under Article 282, par. 2 of the Revised Penal Code.

RULING:

  1. The Court found that there was sufficient evidence to sustain petitioner's conviction of slight physical injuries and of grave threats. The testimonies of Nestor and Julia were found to be more credible and in accord with the natural course of things. The Court also ruled that the lower courts did not err in giving weight to Nestor and Julia's testimonies and disregarding the witness presented by the petitioner.

  2. The Court affirms that the petitioner is guilty of grave threats under Article 282, par. 2 of the Revised Penal Code.

PRINCIPLES:

  • The Supreme Court will not review the finding of facts made by the Court of Appeals, unless there are exceptional circumstances present.

  • It is not within the Court's function to re-evaluate the weight of evidence presented by the parties.

  • Under the Revised Penal Code, there are three kinds of threats: grave threats (Article 282), light threats (Article 283) and other light threats (Article 285).

  • In grave threats, the wrong threatened amounts to a crime which may or may not be accompanied by a condition.

  • In light threats, the wrong threatened does not amount to a crime but is always accompanied by a condition.

  • In other light threats, the wrong threatened does not amount to a crime and there is no condition.

  • Actions speak louder than words. The surrounding circumstances must be considered in determining the nature of the threat.