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Case Digest - US-vs-Maralit

The United States vs. Maximo Maralit involved a homicide case where Maximo Maralit, who was under 15 years old at the time of the crime, stabbed and killed another minor, Florentino. Maralit was convicted and sentenced to 5 years imprisonment. The key issue was whether Maralit was exempt from criminal liability given his age. The Court ruled that while generally those under 15 are exempt, Maralit acted with discernment in committing the crime, so he was criminally liable. However, the Court modified the penalty to 2 years imprisonment given Maralit's status as a minor.

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376 views2 pages

Case Digest - US-vs-Maralit

The United States vs. Maximo Maralit involved a homicide case where Maximo Maralit, who was under 15 years old at the time of the crime, stabbed and killed another minor, Florentino. Maralit was convicted and sentenced to 5 years imprisonment. The key issue was whether Maralit was exempt from criminal liability given his age. The Court ruled that while generally those under 15 are exempt, Maralit acted with discernment in committing the crime, so he was criminally liable. However, the Court modified the penalty to 2 years imprisonment given Maralit's status as a minor.

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Zeresh
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We take content rights seriously. If you suspect this is your content, claim it here.
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THE UNITED STATES, plaintiff and appellee,

vs.

MAXIMO MARALIT, defendant and appellant.

36 Phil. 155

G.R. No. 11979

January 25, 1917.

MORELAND, J.

The appellant, Maximo Maralit, was convicted of homicide and sentenced to five
(5) years of prision correccional, to the accessories provided by law, to indemnify
the heirs of the deceased in the sum of P1,000, and to pay the costs

DOCTRINE:

EXEMPTION FROM RESPONSIBILITY.—A person over 9 years of age and


under 15 is exempt from criminal liability unless, in committing the crime, he
acted with discernment.

FACTS:

1. Two witnesses testified to the occurrence on behalf of the prosecution and stated
that they, with the deceased Florentino, were walking along in single file each with
a bundle of zacate on his head, Florentino bringing up the rear, when they met the
defendant and a companion.

2. As they were passing each other they heard a sound similar to that made by the
dropping of one of the bundles of zacate.

3. They instantly turned and saw Florentino and the defendant fighting with their
fists.

4. They soon separated and Florentino, returning to his bundle of zacate, stooped
to pick it up when the defendant ran to him quickly and stabbed him in the left side
with a knife.

5. The defendant and his companion then ran away. The witnesses and Florentino
went home.
6. Florentino died a few days later as a result of the wound thus received.
1
7. Florentiono, the deceased, was less than 16, the certificate of death stating that
his age was fifteen. Defendant-appellant was less than 15 years of age at the time
the crime was committed.

7. Appellant was convicted of homicide.

ISSUES:

WON defendant-appellant being less than 15 years of age is exempt from criminal
liability

RULING:

NO. The Court ruled that defendant-appellant acted with discernment in


committing the crime, thus is criminally liable under Paragraph 3 Article 8 of the
Penal Code. However, penalty imposed is modified pursuant to Article 85 of the
Penal Code and should have been two (2) years of prision correccional instead of
five years.

The Court held that it is true that it must appear from the evidence that the accused
acted with knowledge of the nature of his acts and of the results which would
naturally follow therefrom; but to establish that fact it is not necessary that some
witness declare directly and in words that he acted with such knowledge. It is
sufficient that, from the evidence as a whole, it is a necessary inference that he so
acted. The trial court taking into consideration all of the facts and circumstance
presented by the record, together with the appearance of the accused as he stood
and testified in court, drew the conclusion that he was of sufficient intelligence and
was sufficiently endowed with judgment to know that the act which he committed
was wrong and that it was likely to produce death. In pursuance of that conclusion
the court made the finding that the accused in committing the act complained of
acted with discernment.

DISCRETIONAL PENALTY.—Where the accused is a minor of less than 15 and


over 9 years of age, a discretional penalty should be imposed, provided that the
same shall always be less by two degrees, at least, than that prescribed by the law
for the offense committed.

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