Case Digest (G.R. No. 201310) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the case of Mark Reynald Marasigan y De Guzman vs. Reginald Fuentes alias "Regie," Robert Calilan alias "Bobby," and Alain Delon Lindo (G.R. No. 201310, January 11, 2016), the facts are as follows: On December 20, 2006, at approximately 3:00 a.m., petitioner Mark Reynald Marasigan was walking home along Hebrew Street, Adelina I Subdivision, Barangay San Antonio, San Pedro, Laguna, when he allegedly became the target of an attack. After passing Fuentes' residence, where a celebration was in progress, an object was thrown at him from behind, which he later identified as having been thrown by Reginald Fuentes. Witness Jefferson Pablo confirmed Fuentes' act. Upon this confrontation, Fuentes returned, accompanied by Calilan and Lindo, who together assaulted Marasigan. The attack escalated when Fuentes attempted to strike Marasigan with a hollow block, leading Marasigan to parry the blow and suffer a fracture in his hand. The assault continued with all
... Case Digest (G.R. No. 201310) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- Petitioner Mark Reynald Marasigan initiated various legal remedies against respondents Reginald Fuentes (Regie), Robert Calilan (Bobby), and Alain Delon Lindo by filing:
- A Petition for Certiorari under Rule 65 before the Court of Appeals challenging earlier decisions.
- A Petition for Review on Certiorari under Rule 45 before the Supreme Court, contesting the Court of Appeals’ dismissals and rulings.
- The case involved multiple decisions:
- The August 19, 2011 Decision of the Court of Appeals dismissed Marasigan’s Petition for Certiorari.
- The February 21, 2012 Resolution of the Court of Appeals denied his Motion for Reconsideration.
- The original September 2, 2009 Resolution by then DOJ Undersecretary Linda L. Malenab-Hornilla partially granted his review petition and directed the filing of criminal informations for attempted murder against the respondents.
- Factual Matrix and Incident Details
- On December 20, 2006, at approximately 3:00 a.m., petitioner Marasigan, while walking home along Hebrew Street in Barangay San Antonio, San Pedro, Laguna, experienced an assault:
- As he passed by Fuentes’ house, an object was thrown at him from behind. Upon turning, he identified Fuentes as the assailant.
- A witness, Jefferson Pablo, confirmed that it was indeed Fuentes who threw the object.
- The assault escalated when:
- Fuentes reappeared along with Calilan, Lindo, and another unidentified individual.
- Fuentes punched Marasigan, causing a nosebleed while Calilan and Lindo also struck him, with an additional accomplice attempting to restrain the petitioner.
- Fuentes gathered a stone (from a hollow block) and tried to hit Marasigan’s head; petitioner parried the blow, fracturing his hand.
- Other men present at Fuentes’ residence joined in the assault.
- Immediate Aftermath and Subsequent Actions
- As the assault intensified—with respondents seemingly set on using construction materials (hollow blocks) to fatally harm Marasigan—he called for help.
- Gregoria Pablo, mother of witness Jefferson Pablo, intervened attempting to pacify the attackers.
- Eventually, neighbors Marcelo Maaba and Lauro Agulto arrived causing the assailants to flee.
- Post-assault, petitioner Marasigan:
- Sought immediate medico-legal examinations (two separate examinations and an x-ray).
- Filed reports/complaints at the barangay hall and the police station.
- Formally lodged a criminal complaint for frustrated murder on December 28, 2006, before the Assistant Provincial Prosecutor.
- Investigative and Prosecutorial Proceedings
- Assistant Provincial Prosecutor Christopher R. Serrano, after a preliminary investigation, issued a resolution on August 16, 2007:
- Determined probable cause to charge Fuentes and Calilan with less serious physical injuries.
- Cleared Lindo of any liability due to absence of qualifying circumstances for murder.
- Petition for Review before the Department of Justice by Marasigan:
- Argued that the medico-legal and other evidences showed a design to kill him, justifying charges of frustrated murder.
- Subsequent administrative resolutions:
- Undersecretary Malenab-Hornilla’s September 2, 2009 Resolution partially granted the petition by ordering the filing of informations for attempted murder against all three respondents.
- Later, on February 8, 2010, Secretary Agnes VST Devanadera issued a resolution reversing Undersecretary Malenab-Hornilla’s order, absolving Fuentes and Lindo, and limiting charges against Calilan to less serious physical injuries.
- Aggrieved by the latter resolution and the Court of Appeals rulings, Marasigan pursued further remedies resulting in the present petition for review on certiorari under Rule 45.
- Evidentiary and Witness Testimonies
- Multiple witnesses provided sworn statements describing:
- The sequence of events and escalation of violence.
- Details of the coordinated assault involving multiple assailants.
- Observations that corroborated the petitioner’s account of being outnumbered and targeted with potentially fatal blows.
- The evidence pointed to:
- An organized and collective action by the respondents.
- The use of superior strength and weaponry (stone/hollow block) intended to kill, as indicated in witness narratives from Marcelo Maaba, Lauro Agulto, and Gregoria Pablo.
Issues:
- Jurisdiction and Correctability of Errors
- Whether the Court of Appeals erred by relying on evidentiary conclusions that amounted to errors of judgment rather than errors of jurisdiction.
- Whether a Petition for Certiorari under Rule 45 was the proper remedy to correct what is alleged to be grave abuse of discretion by Secretary Devanadera in limiting the charges against the respondents.
- Proper Crime Charge Determination
- Whether the evidentiary findings support prosecuting the respondents for less serious physical injuries only, or whether there is sufficient basis for attempting a murder (or attempted murder) charge.
- Whether the coordinated assault, the application of superior strength, and specific overt acts indicating murderous intent (such as the attempted blow to the head with a stone) justify pursuing a charge of attempted murder instead of, or in addition to, frustrated murder.
- Abuse of Discretion and Evidentiary Appreciation
- Whether Secretary Devanadera’s reliance on physical evidence and medico-legal findings, contrary to other corroborative testimonial evidence, constituted a grave abuse of discretion.
- Whether the apparent misapprehension of facts by the prosecuting authorities and the DOJ ruling amounts to a reversible error.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)