Case Digest (G.R. No. 238798) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On October 28, 2003, then 17-year-old CICL XXX and a companion forcibly entered the home of AAA in La Trinidad, Benguet, and struck AAA’s head, left eye, and ear with a blunt instrument. AAA, who had testified against XXX at a barangay hearing the previous day for an unrelated mauling complaint, was found bleeding at his gate by his parents around 3:00 a.m. He was rushed first to Benguet General Hospital and later to Baguio General Hospital, where doctors diagnosed massive cerebral contusions and hemorrhages consistent with blunt‐force trauma. AAA remained in a vegetative state for five years until his death on November 26, 2008, from metabolic encephalopathy secondary to ischemic infarction and acute intraparenchymal hemorrhages. In March 2004, the Regional Trial Court of La Trinidad, Benguet, Branch 9 (RTC) charged XXX with homicide under an amended Information. During trial, the prosecution presented testimony from AAA’s family, police officers, and three doctors; the defense Case Digest (G.R. No. 238798) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- On October 27, 2003, AAA testified against minor CICL XXX (17 years old) in a barangay hearing on a mauling complaint filed by DDD.
- Around 3:00 a.m. on October 28, 2003, BBB (AAA’s mother) and her husband found AAA lying outside their gate with a bloodied face and eyes. AAA, under shock, told them CICL XXX and a companion struck him with a blunt instrument.
- Medical course and death
- October 29–30, 2003: AAA developed dizziness; CT scan revealed severe brain contusions and bleeding. He was transferred to Baguio General Hospital, where physicians found massive cerebral contusions, lacerations, and bruises.
- January 27, 2004: AAA discharged in a vegetative state; bedridden for five years. November 26, 2008: AAA died of metabolic encephalopathy secondary to blunt head trauma.
- Criminal proceedings
- March 2, 2004: RTC Information charged CICL XXX with frustrated murder, later amended to homicide upon AAA’s death.
- 2005–2011: Prosecution presented witnesses (barangay officer, police officer, three doctors, AAA’s mother and sister). Defense presented CICL XXX and his guardian, YYY, who testified he was drinking that night and later worked as a guide in Sagada.
- Lower court rulings
- February 28, 2014 (RTC): Convicted CICL XXX of homicide; sentenced to 8 years & 1 day prision mayor (minimum) to 14 years 8 months & 1 day reclusion temporal (maximum); ordered damages.
- November 29, 2017 (CA): Affirmed but modified penalty to 6 months & 1 day prision correccional (minimum) to 8 years & 1 day prision mayor (maximum); adjusted damages and remanded for RA 9344 disposition.
Issues:
- Whether the CA erred in admitting AAA’s statements to his mother as part of the res gestae exception to the hearsay rule.
- Whether AAA’s death was proximately caused by CICL XXX’s assault or by delayed/inadequate medical treatment.
- Whether the elements of homicide were established against CICL XXX.
- Whether CICL XXX acted with discernment—exempting him from criminal liability under Section 6 of RA 9344.
- Whether the failure to allege and discuss discernment in the Information and RTC decision required acquittal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)