Case Digest (G.R. No. 125838) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Rolly Adriano y Samson, G.R. No. 205228, decided July 15, 2015 under the 1987 Constitution, the accused-appellant Rolly Adriano y Samson (Appellant) was tried alongside co-accused Lean Adriano @ Denden, Abba Santiago y Adriano, John Doe, and Peter Doe for two separate killings that occurred on March 13, 2007 at around 8:00 a.m. on Olongapo-Gapan National Road, Barangay Malapit, San Isidro, Nueva Ecija. In Criminal Case No. 13159-07, Appellant stood charged with the homicide of bystander Ofelia Bulanan, who died from a stray bullet, while in Criminal Case No. 13160-07, he was charged with murder of Danilo Cabiedes, the driver of a maroon Honda CR-V. Trial evidence showed that Police Officer 1 Matthew Garabiles and PO2 Alejandro Santos, in civilian clothes, witnessed a blue Toyota Corolla (leased by Appellant) overtake the CR-V, discharge several shots resulting in Cabiedes’s death at Good Samaritan General Hospital and Bulanan’s immediate death at Case Digest (G.R. No. 125838) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural History
- Regional Trial Court (RTC) of Gapan City, Nueva Ecija, Branch 36, convicted Rolly Adriano y Samson for:
- Homicide (Crim. Case No. 13159-07) for the killing of Ofelia Bulanan.
- Murder (Crim. Case No. 13160-07) for the killing of Danilo Cabiedes.
- Court of Appeals (CA) in CA-G.R. CR-HC No. 04028 affirmed the RTC decision on 30 May 2011.
- The Supreme Court consolidated the appeal and promulgated its decision on 15 July 2015.
- Incident Description
- On March 13, 2007 at around 8 a.m. along Olongapo-Gapan National Road, Barangay Malapit, San Isidro, Nueva Ecija, a blue Toyota Corolla (plate WHK 635) overtook a maroon Honda CRV (plate CTL 957) occupied by Danilo Cabiedes.
- The front-seat passenger of the Corolla fired shots at the CRV, causing it to swerve into a canal. Four armed men then shot Cabiedes; a stray bullet struck bystander Ofelia Bulanan.
- Bulanan died on the spot (head wound); Cabiedes was pronounced dead on arrival at Good Samaritan General Hospital (three gunshot wounds to the chest).
- Investigation and Arrest
- The Corolla was registered to Antonio Y. Rivera, who admitted leasing it to Adriano. Police Officers 1 and 2, Matthew Garabiles and Alejandro Santos, positively identified Adriano as one of the assailants.
- Adriano was arrested later that day at Rivera’s shop; the PSOG headquarters recovered one deformed bullet and five .45-caliber cartridges.
- Defense alibi: Adriano claimed he was in Dolores, Magalang, Pampanga, washing clothes, fetching motorcycle repairs, visiting friends, and watching cockfights between 6 a.m. and 5 p.m.; corroborated by four relatives/friends.
Issues:
- Whether Adriano’s defense of alibi was sufficiently proven to create reasonable doubt.
- Whether minor inconsistencies in the testimonies of PO1 Garabiles and PO2 Santos undermine their positive identification of Adriano.
- Whether the killings constitute a complex crime or separate offenses, and whether qualifying circumstances were properly appreciated.
- Whether the computation and quantum of actual, moral, exemplary, and temperate damages awarded are correct.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)