Case Digest (G.R. No. 187536) Core Legal Reasoning Model
Facts:
The case concerns appellants Michael Bokingco (alias Michael Bokingo) and Reynante Col, accused of murdering Noli Pasion in Angeles City on February 29, 2000. Pasion owned a pawnshop and residential units where both appellants, as construction workers, worked or stayed. At around 1:00 a.m., witnesses heard a commotion in Apartment No. 3, where Bokingco resided. Dante Vitalicio, Pasion's brother-in-law and tenant of Apartment No. 5, witnessed Bokingco attacking and hitting something on the floor with a hammer. In a confrontation, Vitalicio was also assaulted but managed to fend off Bokingco. Pasion was found dead on the kitchen floor with fatal hammer wounds. Elsa, Pasion's wife, testified that Col blocked her while she was going downstairs, sprayed tear gas into her eyes, and threatened her with a sharp object while demanding she open the pawnshop vault. Col and Bokingco fled the scene together after Elsa refused to comply. Police investigation found a claw hammer near
Case Digest (G.R. No. 187536) Expanded Legal Reasoning Model
Facts:
- Parties and Charges
- Michael Bokingco (also known as Michael Bokingo) and Reynante Col were charged with murder.
- The crime allegedly occurred on February 29, 2000, in Angeles City, involving the victim Noli Pasion.
- Both accused were charged with murder qualified by treachery, evident premeditation, abuse of confidence, and nighttime attendance.
- Incident Details
- Bokingco and Col were construction workers employed by Pasion at his property.
- Pasion lived at a house with a pawnshop in front and apartments at the back; accused lived in Apartment No. 3.
- Around 1:00 a.m., Vitalicio (brother-in-law to Pasion, leasing apartment no. 5) heard commotion and saw Bokingco hitting something on the floor.
- Vitalicio was attacked by Bokingco with a hammer but managed to fend off and escape.
- Elsa, Pasion's wife, heard noises and tried to intervene but was blocked and attacked by Col with tear gas and a sharp object.
- Elsa saw Bokingco and Col flee the premises after she refused to open the pawnshop vault under duress.
- Investigation and Evidence
- Police found the hammer near the kitchen sink and blood on the floor.
- Medical examiner Dr. Joven G. Esguerra confirmed Pasion suffered multiple fatal contusions and lacerations, including depressed skull fractures with brain tissue damage.
- Bokingco initially pleaded guilty and confessed to conspiring with Col to kill Pasion during preliminary investigation.
- Col denied knowledge of Bokingco and stated he resigned days before the incident.
- Court Proceedings
- Trial court convicted both accused of murder and sentenced them to death.
- The Court of Appeals affirmed conviction but reduced penalty to reclusion perpetua pursuant to RA 7659 and RA 9346.
- The acquittal of Col was eventually ordered by the Supreme Court due to insufficient evidence of conspiracy; Bokingco was convicted of homicide with a reduced sentence.
Issues:
- Whether the qualifying circumstances of treachery, evident premeditation, abuse of confidence, and nighttime were proven to elevate the crime from homicide to murder against Bokingco.
- Whether Reynante Col is guilty beyond reasonable doubt as a co-conspirator in the murder of Noli Pasion.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)