Case Digest (G.R. No. 102786) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the afternoon of April 18, 1989, Alexander Manalo and Felino Olegario of the Manila Electric Company (MERALCO) discovered that six electric meters installed at the premises of Cathay Pacific Steel and Smelting Corporation (CAPASSCO) in Novaliches, Quezon City, were missing. They reported the loss to MERALCO’s Ortigas Avenue office and later gave sworn statements to the Northern Police District on April 20, 1989, suspecting tampering by CAPASSCO employees or MERALCO personnel. Patrolman Edgar Enopia’s inquiry led him to Danilo Garcia, who on July 4, 1989, identified four men in MERALCO service truck No. 522—one of whom was Alejandro B. de la Torre, the petitioner—during a police line‐up at Camp Karingal. Based on these statements, Assistant City Prosecutor Demetrio Macapagal filed an information on July 13, 1989, charging de la Torre with Qualified Theft (Arts. 309 and 310, Revised Penal Code) for unlawful removal of six meters valued at ₱41,786.00. Trial before RTC Branch 92, Case Digest (G.R. No. 102786) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and discovery of loss
- On April 18, 1989, Alexander Manalo of MERALCO discovered six electric meters missing from CAPASSCO premises in Novaliches, Quezon City.
- Manalo reported the loss and, along with Felino Olegario, gave statements to the Northern Police District on April 20, 1989.
- Police investigation and identification
- Patrolman Edgar Enopia inquired locally; Danilo Garcia reported seeing four MERALCO crew members in truck no. 522 removing meters on April 11, 1989.
- On July 4, 1989, a police line-up of eight MERALCO men was held; Garcia identified petitioner Alejandro B. de la Torre as leader.
- Criminal proceedings
- On July 13, 1989, an information for qualified theft (Art. 309, RPC) was filed against de la Torre, alleging removal of six meters valued at ₱41,786.00.
- RTC Branch 92 convicted de la Torre (Mar. 16, 1990) sentencing him to 6 years, 1 month, 11 days to 8 years, 1 day prision mayor plus indemnity.
- The Court of Appeals affirmed (June 18, 1991) and denied reconsideration; de la Torre appealed to the Supreme Court.
Issues:
- Whether petitioner’s constitutional right to be informed of the right to remain silent and to counsel was violated during the July 4, 1989 line-up.
- Whether the RTC erred in admitting testimonies without formal offer under Rule 132, Secs. 34-36, Rules of Court.
- Whether hearsay certifications (Exhs. M, N, P) were improperly considered despite absence of declarants for cross-examination.
- Whether the uncorroborated testimony of Danilo Garcia was sufficient to prove guilt beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)