Case Digest (G.R. No. 264913) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the case of People of the Philippines vs. Ronald Paradero Aporado, decided on February 5, 2024, the accused Ronald Paradero Aporado was charged with murder under Article 248 of the Revised Penal Code for stabbing Amado B. Halasan on January 28, 2017, in the Municipality of Bansalan, Province of Davao del Sur. The incident occurred during a drinking spree involving Ronald, Amado, and others. Ronald was mocked and challenged by the group, particularly by Amado, which enraged him. Ronald left to go home but returned armed with a knife and stabbed Amado multiple times, allegedly shouting that he knew how to kill. Amado was found dead on arrival at the hospital. Ronald was arrested by barangay tanod Janilo Espinosa, who found a knife in Ronald’s backpack. Ronald admitted to stabbing Amado but disputed some details, such as returning to stab Amado a second time. The Regional Trial Court (RTC) convicted Ronald of murder, citing the presence of treachery since the victim was asleep a Case Digest (G.R. No. 264913) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charges and Initial Plea
- Ronald Paradero Aporado was charged with murder for stabbing Amado B. Halasan on January 28, 2017, in Bansalan, Davao del Sur.
- The Information alleged he stabbed Amado with a bolo using treachery, causing instantaneous death.
- Ronald pleaded not guilty at arraignment.
- Incident Details
- On the date of the crime, Ronald, Amado, Jay Amoy, and Fritz Montalba were drinking outside Jomar Amoy’s house.
- Ronald was teased by the group, who said he looked like a killer and was ugly.
- Amado challenged if Ronald knew how to kill a person.
- Ronald was angered but initially endured the teasing.
- After a call from his sister, Ronald went home but returned with a knife.
- The Killing
- Upon returning, Jay offered Ronald a drink; Ronald then tried to punch Amado but was restrained.
- Jay saw Ronald stab Amado several times in the chest.
- Amado was asleep with his head bowed when stabbed.
- Ronald left, warning that he would kill them all.
- Arrest and Statements
- Barangay tanod Janilo Espinosa apprehended Ronald on the road and found a knife in his backpack.
- Ronald admitted stabbing Amado and said he liked to kill.
- Defense
- Ronald admitted stabbing Amado five times but denied the second stabbing.
- He claimed to have gone to surrender but unknowingly flagged down a barangay-owned vehicle leading to his arrest.
- Trial Court Decision
- RTC convicted Ronald of murder, finding treachery due to multiple stabbings of sleeping victim.
- Sentence: Reclusion perpetua plus damages of PHP 47,795 (actual), PHP 100,000 (moral), and PHP 100,000 (exemplary).
- Court of Appeals
- CA affirmed the conviction and rejection of mitigating circumstances: passion and obfuscation, sufficient provocation, voluntary surrender.
- Ronald's appeal and motion for reconsideration denied.
- Supreme Court Appeal
- Ronald claims lack of proof on treachery and entitlement to mitigating circumstances.
Issues:
- Whether the element of treachery, which qualifies homicide to murder, was proven beyond reasonable doubt.
- Whether the accused is entitled to mitigating circumstances: sufficient provocation, passion and obfuscation, voluntary surrender, and intoxication.
- Proper penalty to be imposed considering the findings on the presence or absence of treachery and mitigating circumstances.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)