Case Digest (G.R. No. 164201) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Efren Pana v. Heirs of Jose Juanite, Sr., G.R. No. 164201, decided on December 10, 2012 under the 1987 Constitution, petitioner Efren Pana and his wife Melecia, together with others, were charged with murder in RTC Surigao City Criminal Cases Nos. 4232 and 4233. On July 9, 1997, the RTC acquitted Efren for insufficiency of evidence but found Melecia guilty, sentencing her to death and ordering her to pay each heir of the victims ₱50,000 as civil indemnity, ₱50,000 as moral damages, and ₱150,000 as actual damages. On appeal, the Supreme Court on May 24, 2001 modified Melecia’s penalty to reclusion perpetua, affirmed the indemnity and moral damages, deleted actual damages due to lack of proof, substituted temperate damages of ₱15,000 each, and added exemplary damages of ₱50,000 per victim. The decision became final on October 1, 2001. Upon the heirs’ motion for execution, the RTC on March 12, 2002 issued a writ of execution levying real properties titled in the names of Efren a Case Digest (G.R. No. 164201) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Criminal Proceedings
- The Regional Trial Court (RTC) of Surigao City charged Efren Pana, his wife Melecia, and others with murder in Criminal Cases Nos. 4232 and 4233. On July 9, 1997, the RTC acquitted Efren for insufficiency of evidence but convicted Melecia and a co-accused, sentencing them to death and ordering them to pay each heir of the victims:
- ₱50,000 civil indemnity
- ₱50,000 moral damages
- ₱150,000 actual damages
- On appeal, this Court (May 24, 2001) affirmed the convictions as reclusion perpetua, upheld civil indemnity and moral damages, deleted actual damages for lack of proof, awarded temperate damages of ₱15,000 each, and imposed exemplary damages of ₱50,000 per victim, to be paid solidarily. The decision became final on October 1, 2001.
- Execution Against Spouses’ Properties
- Upon motion of the heirs, the RTC on March 12, 2002 issued a writ of execution, resulting in the levy of real properties titled in the names of Efren and Melecia. Notices of levy and sale were issued.
- On April 3, 2002, Efren and Melecia moved to quash the writ, arguing that the levied properties were conjugal (not paraphernal) assets. The RTC denied the motion on September 16, 2002, and denied reconsideration on March 6, 2003.
- The spouses filed a certiorari petition with the Court of Appeals (CA), which was dismissed on January 29, 2004 for failure to show grave abuse of discretion; reconsideration was denied on May 14, 2004. Efren then filed the present petition for review on certiorari.
Issues:
- Whether the conjugal properties of Efren and Melecia Pana, acquired under the conjugal partnership of gains, may be levied and executed upon to satisfy the civil indemnities and damages imposed on Melecia for her criminal liability in the murder case.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)