Case Digest (G.R. No. 143647) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Erpascual Diega y Pajares v. Court of Appeals and People of the Philippines v. Erpascual Diega y Pajares, decided en banc on March 15, 2010 (G.R. Nos. 173510 and 174099), petitioner Diega served as a stay-in security guard at a 50-hectare farm in Upper Ciudad Real, Araneta, San Jose del Monte, Bulacan. On or about March 17, 1995, the 13-year-old victim (“AAA”) who routinely passed through the plantation on her way to and from school failed to return home. The following morning her body was discovered in the farm, strangled with a wood vine, bearing deep wounds and signs of forced carnal knowledge. Medico-legal findings indicated asphyxia by strangulation and hymenal lacerations consistent with recent loss of virginity. Witness Juanito Manalo III testified that between 1:00 and 2:00 p.m. of March 17 he saw Diega, clad only in shorts, waving a pistol to compel him to tie a vine around the unconscious victim’s neck and threaten him into silence. Co-workers Martin Gailan and Arne Case Digest (G.R. No. 143647) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Appellant Erpascual Diega y Pajares was employed as a stay-in security guard in a 50-hectare plantation at Upper Ciudad Real, Araneta, San Jose del Monte, Bulacan.
- Victim “AAA” was a 13-year-old first-year high school student residing in Rodriguez, Rizal, who routinely walked through the plantation en route to and from school.
- Disappearance and Discovery
- On March 17, 1995, “AAA” failed to return home at her usual hour; on the morning of March 18, her body was found inside the plantation, covered with leaves, with a wood vine tied around her neck, head wounds, a crumpled uniform, and missing undergarments.
- The scene, near a banana grove, bore no eyewitnesses to the assault but indicated violent attack and sexual violation.
- Forensic and Ocular Evidence
- A medico-legal examination about 24 hours after death showed asphyxia by strangulation, hemorrhages from traumatic injuries, deep fresh lacerations on the hymen compatible with recent loss of virginity, and defensive wounds on the left forearm.
- Upon his apprehension, the appellant exhibited fresh scratches on his arms, neck, and back, consistent with fingernail marks.
- Witness Testimonies
- Juanito Manalo III testified that between 1:00 and 2:00 p.m. on March 17, he saw the appellant, clad only in shorts and wielding a pistol, stooping over an unconscious “AAA,” then forced him under threat of death to tie a vine around her neck and threatened to kill him and his family if he spoke.
- Martin Gailan and Arnel Alminana corroborated the threats, observed Juanito fleeing the scene, and confirmed the appellant’s prior unexplained absences from his post and lewd interest in “AAA.”
- Appellant’s Defense and Conduct
- The appellant denied knowing “AAA,” claimed an alibi placing him elsewhere from midnight until mid-afternoon on the incident day, and alleged false accusation motivated by a land dispute and his complaints about trespassing livestock.
- He voluntarily surrendered and was released multiple times without charges, gave a statement without counsel, withdrew counsel’s waiver, absconded before the arrest warrant issued, and was finally arrested in October 1997 in Northern Samar.
Issues:
- Whether the circumstantial evidence forms an unbroken chain pointing exclusively to the appellant’s guilt for the complex crime of rape with homicide.
- Whether the appellant was denied due process by an alleged unlawful arrest and preparation of statements without counsel or proper judicial examination of witnesses.
- Whether the appellant’s defences of denial and alibi were supported by evidence sufficient to raise reasonable doubt.
- Whether the penalty and damages imposed by the appellate court should be affirmed or modified.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)