Title
Callo-Claridad vs. Esteban
Case
G.R. No. 191567
Decision Date
Mar 20, 2013
Chase Claridad found dead in Quezon City; last seen with Philip Esteban. Insufficient evidence led to dismissal of murder charges; Supreme Court upheld decision, citing lack of probable cause.

Case Digest (G.R. No. 191567)
Expanded Legal Reasoning Model

Facts:

  • Parties and victim
    • Petitioner: Marie Callo-Claridad, mother of the late Cheasare Armani “Chasea” Claridad.
    • Respondents: Philip Ronald P. Esteban and Teodora Alyn Esteban.
  • Circumstances of the killing
    • On February 27, 2007 Chasea’s body was found at about 7:50 p.m. between cars parked at the carport of No. 10 Cedar Place, Ferndale Homes, Quezon City. He was naked from the waist up, bloodied, with two stab wounds (one piercing the heart).
    • Chasea was last seen alive between 7:00 and 7:30 p.m. boarding a white Honda Civic (plate CRD 999) allegedly driven by Philip. Security guard logs recorded Philip’s arrival at 7:26 p.m. with a male companion.
  • Crime-scene processing and medico-legal findings
    • Scene-of-Crime Operations (SOCO) sketched and photographed the scene, recovered bloodstained items (shirt, phone, nylon cord) and the cadaver.
    • NBI Medico-Legal Report: two stab wounds—one on the lower chest (9 cm deep, fractured 4th rib, pierced heart) and one on the forearm—corroborated by PNP report.
  • Preliminary investigation and administrative remedies
    • The Office of the City Prosecutor (OCP) of Quezon City dismissed the complaint for lack of probable cause on December 18, 2007; motion for reconsideration denied December 15, 2008.
    • Secretary of Justice affirmed dismissal on April 16, 2009 (denial of reconsideration May 21, 2009).
    • Petition for review under Rule 43 was filed in the Court of Appeals (CA), which on November 20, 2009 dismissed the petition and denied reconsideration.

Issues:

  • Whether the CA erred in upholding the Secretary of Justice’s finding of no probable cause to charge Philip and Teodora with murder.
  • Whether the petitioner’s mode of appeal (Rule 43 petition) was proper.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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