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PEOPLE v. LOPEZ @ "DODONG,"G.R. No. 232247 | 2018

Supreme Court Upholds Parricide Conviction in People v. Lopez

G.R. No. 232247 | April 23, 2018

People of the Philippines vs. Ronillo Lopez Jr. y Mantalaba ("Dodong") Ponente: Justice Peralta

📌 Full text: .

Nature of the Case

This appeal challenges the January 6, 2017 Decision of the Court of Appeals (CA) in CA-G.R. CR-HC No. 07936, which affirmed the December 1, 2015 ruling of the Regional Trial Court, Branch 197, Las Piñas City. The lower court found Ronillo Lopez Jr. guilty beyond reasonable doubt of parricide under Article 246 of the Revised Penal Code for killing his father, Ronillo Lopez Sr.

Court Ruling

✅ Appeal DISMISSED. ✅ Guilty verdict AFFIRMED with modifications:

  • Reclusion perpetua without parole.

  • Actual damages: ₱60,000.

  • Civil indemnity: ₱75,000.

  • Moral damages: ₱75,000.

  • Exemplary damages: ₱75,000.

  • 6% per annum interest on damages until fully paid.

Key Doctrines in Criminal Law

✔️ Burden of Proof in Self-Defense Claims 📌 When an accused pleads self-defense, they admit to killing the victim and must prove all elements of self-defense with clear and convincing evidence.

✔️ Elements of Justifiable Self-Defense For self-defense to be upheld, the following three requisites must be proven: 1️⃣ Unlawful aggression by the victim, posing an actual or imminent threat. 2️⃣ Reasonable necessity of the means used to repel aggression. 3️⃣ Lack of sufficient provocation from the accused.

📌 Without unlawful aggression, self-defense cannot be legally upheld.

✔️ Unlawful Aggression Defined Unlawful aggression requires:

  • A physical attack or assault.

  • The attack to be actual or imminent.

  • The attack to be unlawful.

📌 Imagined or speculative threats do not qualify as unlawful aggression.

✔️ Failure to Establish Self-Defense 📌 Self-defense cannot be appreciated if it lacks competent evidence or appears doubtful. 📌 The accused must fully exclude any criminal intent in their defense.

Case Summary

🔹 Crime Details

  • Ronillo Lopez Jr. fatally stabbed his father.

  • He admitted the killing but claimed self-defense.

  • The victim’s mother testified that Ronillo himself called for help, revealing he had stabbed his father.

  • Physical evidence contradicted his claim, as no sign of unlawful aggression from the victim was found.

🔹 Court’s Findings ✅ Self-defense not applicable: Ronillo failed to prove unlawful aggression by his father. ✅ Parricide conviction upheld:

  • The victim was unarmed, contradicting Ronillo’s self-defense claim.

  • Ronillo’s call for help weakened his defense, as he immediately admitted stabbing his father. ✅ Guilty of parricide beyond reasonable doubt.

📌 Final Verdict: Conviction upheld with increased damages and penalties.

Conclusion

The Supreme Court affirmed Ronillo Lopez Jr.’s parricide conviction, ruling that his self-defense claim was unsubstantiated and that he admitted to stabbing his father without proving any legal justification. This case highlights the strict legal requirements for self-defense and reinforces that mere threats or weak allegations do not justify homicide under Philippine law.

📌 For full details, read the official ruling: .

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