Criminal Law

Felipe Navarro vs Court of Appeals

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G.R. No. 121087 – 372 Phil. 21 – Criminal Law – Book I – Aggravating Circumstances – Crime Committed in Places where Official duties are discharged

Enrique Lingan and Stanley Jalbuena, both radio reporters went to a police station to report an incident. During the course, a heated argument arose between police officer Felipe Navarro and the two reporters. Navarro then poked his cocked firearm on the face of Jalbuena. Lingan interfered, this then irked Navarro and another argument ensued. Lingan then challenged Navarro to divest himself of his gun so that they can have a fistfight. Thereafter, Navarro mauled Lingan which resulted in Lingan’s death. Navarro was convicted for homicide.

ISSUE: Whether or not there is an aggravating circumstance against Navarro due to the fact that he committed such crime in the police station?

HELD: Yes. A police station is a place where public authorities such as policemen are engaged in the discharge of their duties. Since Navarro, who is a cop, committed the crime inside the police station, an aggravating circumstance is appreciated against him.

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