Case Digest (G.R. No. 212483) Core Legal Reasoning Model
Facts:
The petitioner, Reynaldo S. Mariano, was charged by the Office of the Provincial Prosecutor of Bulacan with frustrated murder for hitting and bumping Ferdinand de Leon with the motor vehicle he was driving on or about September 12, 1999, in Angat, Bulacan. The complaint alleged that Mariano committed the offense with evident premeditation, treachery, and abuse of superior strength when he hit Ferdinand with his pick-up truck, inflicting serious injuries that could have caused death, which was averted only due to timely medical assistance.
The case stemmed from an earlier road incident where Mariano’s red Toyota pick-up almost bumped Ferdinand’s jeepney while overtaking. An altercation ensued but was pacified by a relative, Luis de Leon. Later, when Ferdinand alighted his jeepney in front of his mother’s house, he was hit and injured by Mariano’s pick-up traveling at a fast speed. Mariano claimed the incident was accidental, saying Ferdinand suddenly alighted and lost balance. A
Case Digest (G.R. No. 212483) Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Reynaldo S. Mariano (petitioner) was charged with frustrated murder for hitting and bumping Ferdinand de Leon using his motor vehicle on September 12, 1999, in Angat, Bulacan.
- Ferdinand de Leon was driving his jeepney with his family when Mariano's pick-up overtook and almost bumped his vehicle, which led to an altercation and subsequent incident causing de Leon's injuries.
- After the incident, Mariano voluntarily surrendered at Camp Alejo S. Santos in Malolos, Bulacan.
- Incident Details
- The initial road incident involved Mariano overtaking de Leon’s jeepney at a fast speed in Barangay Engkanto, Angat, Bulacan.
- Following a verbal altercation, Ferdinand stopped at his mother’s house in San Roque and parked. He was then struck by Mariano’s moving pick-up truck and thrown about four meters, causing serious injuries.
- Mariano asserted that de Leon suddenly alighted from his jeep and lost balance, leading to the collision. He also claimed he stopped his vehicle after allowing an oncoming vehicle to pass and that he fled fearing harm from bystanders.
- Injuries and Medical Expenses
- Ferdinand suffered multiple facial injuries, a fracture on the inferior right orbital wall, and subdural hemorrhage due to severe head trauma.
- He was hospitalized first for two and a half days at Sto. Niño Hospital, Bulacan, then transferred to St. Luke’s Medical Center in Quezon City, staying there until September 25, 1999, with total medical expenses exceeding P86,000 and additional payments for medicines, doctor’s fees, and caregivers amounting to over P21,000.
- Ferdinand became stuporous and temporarily incapacitated, unable to work at his store for approximately three months.
- Trial and Decisions
- The RTC convicted Mariano of frustrated homicide, sentencing him to indeterminate prison terms and awarding damages to Ferdinand.
- On appeal, the CA modified the conviction to reckless imprudence resulting in serious physical injuries with a lesser penalty and lower damages awarded.
- Mariano appealed, arguing absence of criminal intent, lack of negligence, and reliance on voluntary surrender as mitigating circumstances.
Issues:
- Whether petitioner Mariano’s act constituted the crime of frustrated murder, frustrated homicide, or reckless imprudence resulting in serious physical injuries.
- Whether petitioner’s guilt was proven beyond reasonable doubt, including presence or absence of criminal intent or negligence.
- Whether the penalty imposed corresponded correctly to the offense committed.
- Whether voluntary surrender should be considered as a mitigating circumstance in favor of the petitioner.
- Whether the award of damages was correctly computed and justifiable.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)