Case Digest (G.R. No. 243805) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People v. Lacson, petitioner Eduardo Lacson y Manalo, together with co-accused Hernani M. Lacson, Elizer M. Lacson, Deborah Samson-Lacson, Adonis M. Lacson, and Erwin M. Lacson, faced six separate Amended Informations for Attempted Homicide filed on May 11, 2011 before the Municipal Trial Court in Cities (MTCC) of San Fernando, Pampanga. The Informations alleged that on May 5, 2011, at around 9:00 PM in Barangay San Agustin, City of San Fernando, Pampanga, the Lacsons, with intent to kill, willfully attacked six members of the Santos family—Gary, Rudy, Richard, Romeo, Albert, and Rommel Santos—using steel pipes, inflicting wounds on various body parts but stopping short of homicide due to the intervention of bystanders. Upon arraignment, all accused pleaded not guilty. During trial, the prosecution presented six witnesses, including four injured Santoses and Dr. Duane P. Cordero, who testified that the victims’ injuries required healing periods ranging from two weeks to eight Case Digest (G.R. No. 243805) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Nature and Origin of the Case
- Petition for Review on Certiorari filed by Eduardo Lacson y Manalo assailing the CA Decision (12 September 2018) and Resolution (18 December 2018) in CA-G.R. CR No. 40456, which affirmed his conviction for Less Serious Physical Injuries under Article 265, RPC.
- Originated from six (6) Amended Informations for Attempted Homicide (Criminal Cases Nos. 11-0287 to 11-0292) filed on 11 May 2011 before MTCC-Branch 1, City of San Fernando, Pampanga, against Eduardo and co-accused Hernani, Elizer, Deborah, Adonis, and Erwin Lacson.
- Allegations and Trial Proceedings
- On 5 May 2011 at around 9:00 P.M., members of the Santos family (Gary, Arnold, Eliza, Joyce Ann) were pursued and stoned by some Lacsons. Arnold confronted Hernani and Elizer at the Lacson residence. Deborah Lacson handed Eduardo a steel pipe, which he used to strike Arnold’s head and then attacked Rommel, Gary, Richard, Romeo, and Albert Santos.
- The victims sustained lacerations, contusions, and fractures; treated by Dr. Duane P. Cordero whose medical certificates showed healing periods ranging from two (2) to eight (8) weeks; Arnold died in a separate case.
- Prosecution presented six (6) witnesses: Rommel M. Santos, Gary M. Santos, Richard M. Santos, Rowena L. Santos-Cunanan, Romeo L. Santos, and Dr. Cordero. The defense presented none.
- Lower Court Findings and Sentences
- MTCC (18 February 2016): Found Eduardo and co-accused guilty of Less Serious Physical Injuries (Art. 265, RPC); sentenced to maximum arresto mayor; awarded actual damages of ₱13,363 and legal expenses of ₱50,000; acquitted on some counts for attempted homicide.
- RTC (30 January 2017): Affirmed MTCC Decision in toto; denied motion for reconsideration.
- CA (12 September 2018 Decision; 18 December 2018 Resolution): Dismissed petition; affirmed RTC Decision.
Issues:
- Whether the CA erred in convicting Eduardo of Less Serious Physical Injuries when his personal participation in inflicting injuries was not established.
- Whether conspiracy was sufficiently proven to hold Eduardo liable for his co-accused’s acts.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)