Case Digest (G.R. No. 80645) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Patricio Amigo, G.R. No. 116719 decided on January 18, 1996, the accused-appellant Patricio Amigo, alias “Bebot,” was originally charged with frustrated murder for stabbing Benito Ng Suy multiple times on December 29, 1989 in Davao City. After Ng Suy succumbed to sepsis following extensive medical treatment, an amended Information charged Amigo with murder under Article 248 of the Revised Penal Code. At trial, evidence showed that a vehicular collision between Ng Suy’s Ford Fiera and an orange Toyota Tamaraw carrying Amigo and driver Virgilio Abogada led to a heated exchange. Amigo, provoked by remarks about Ng Suy’s ethnicity, retrieved a five-inch knife and stabbed the victim thirteen times despite pleas for mercy from onlookers and Ng Suy’s daughter. The trial court found Amigo guilty of murder and sentenced him to reclusion perpetua, without recognizing any mitigating or aggravating circumstances, ordering him to pay actual, compensatory, and Case Digest (G.R. No. 80645) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Case
- Initial Information
- Accused: Patricio Amigo alias “Bebot”
- Original Charge: Frustrated murder under Art. 248, RPC in relation to Art. 5, RPC
- Allegations: On December 29, 1989 in Davao City, accused, armed with a knife and employing treachery and premeditation, stabbed victim Benito Ng Suy multiple times (arm, chest, abdomen, thigh) inflicting life-threatening injuries. Medical intervention prevented death.
- Amended Information
- Change of Offense: After Benito Ng Suy’s death, information amended to murder under Art. 248, RPC
- Allegations: Same factual predicate as frustrated murder, but resultant death of victim and damage to heirs
- Factual Circumstances of the Incident
- Traffic Accident and Confrontation
- On December 29, 1989 at about 1:00 PM, Benito Ng Suy was driving a Ford Fiera with family aboard. An orange Toyota Tamaraw driven by Virgilio Abogada (with accused as passenger) made a sudden turn, causing a minor collision.
- Benito alighted and confronted Virgilio. Accused intervened, urging Benito to leave. An exchange of insults ensued, including ethnic slur “You are Chinese,” which angered the accused.
- Stabbing and Flight
- Accused left but returned, repeated ethnic query, then drew a five-inch knife and stabbed Benito twice in the chest. Benito tried to flee; accused chased and inflicted further stab wounds.
- Jocelyn Ng Suy (victim’s daughter) pleaded for mercy; accused ceased only when victim’s younger daughter intervened. Accused fled, Jocelyn tended to father and transported him to hospital.
- Benito underwent surgery, was transferred to Chinese General Hospital, but died three weeks later from sepsis due to multiple stab wounds.
- Procedural History
- Trial Court Decision
- Findings: Accused guilty beyond reasonable doubt of murder with treachery and premeditation (Art. 248, RPC)
- Sentence: Reclusion perpetua; civil indemnity of ₱93,214.70 actual, ₱50,000 compensatory, ₱50,000 moral damages
- Appeal
- Accused’s Argument: Under Sec. 19(1), Art. III, 1987 Constitution (abolition of death penalty), maximum penalty for murder should be reclusion temporal in its medium period (17 years, 4 months, 1 day to 20 years) rather than reclusion perpetua
Issues:
- Whether the trial court erred in imposing reclusion perpetua given Section 19(1), Article III of the 1987 Constitution, which proscribes the death penalty and reduces any imposed death sentence to reclusion perpetua.
- Whether the penalty of reclusion perpetua is unconstitutionally cruel and inhuman, warranting reduction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)