G.R. No. L-16223-25 - Reotan vs. National Rice and Corn Corp.

Case Digest (G.R. No. L-16223-25)
Expanded Legal Reasoning Model

Facts:

Chronology of Events

On or about December 31, 1978, in Asin, Municipality of Sablan, Benguet, the accused allegedly conspired and acted in a premeditated manner.
Emeterio N. Pascua was invited by his friend Francisco Iday to celebrate the New Year; after visiting Pascua’s house, they planned to go to the Rimando Hotel where Pascua’s wife preferred not to have drinks at home.
Before leaving, Pascua sent Iday to purchase liquor at a nearby store with an arrangement to meet at the hotel.
At the store, Iday encountered the appellants, who inquired about his origin, but upon not receiving a clear answer, they left.
Later, on his way to the hotel after purchasing liquor, Iday observed suspicious behavior:

He saw the accused Bisaya retrieving bolos hidden under shrubs.
The appellants were noted carrying bolos, sheathed in scabbards, slung on their shoulders.

Subsequently, as Iday returned home and then headed to fetch water for his wife, he observed Pascua walking toward a store.
The accused, having crossed to the other side of a creek, positioned themselves by the roadside and suddenly attacked Pascua with their bolos.
After the assault, the accused fled from the scene.

Evidence and Medical Findings

Dr. Felicisimo C. del Rosario performed a post-mortem examination on Pascua’s cadaver.
The findings included:

Multiple hacking wounds on the neck, face, hands, and other parts.
Specifically, two hack wounds that severed important structures such as the trachea, esophagus, and blood vessels on the right nape of the neck.
Additional wounds on the jaw and the right wrist, which contributed to cardio-respiratory arrest due to shock and hemorrhages.

The injuries were consistent with being inflicted by a sharp-bladed instrument and could have been caused by one or more persons.

Prosecution’s Case and Testimonies

The prosecution charged the appellants with murder, emphasizing:

The presence of an aggravating circumstance – the commission of the crime at nighttime.
The deliberate, unlawful, and felonious assault resulting in death.

The sole eyewitness, Francisco Iday, testified as follows:

He witnessed the appellants’ suspicious actions before the attack.
He observed the accused’s proximity to the crime scene and noted the retrieval of bolos.
His testimony was bolstered by physical evidence, including photographs (Exhibits “K”, “K-1”, “L”, and “L-1”) demonstrating that the illumination from a street lamp, a hotel electric bulb, and a bonfire provided adequate lighting, thereby refuting the defense argument regarding poor visibility.

Iday also mentioned that he had been aware of an ongoing animosity between Pascua and the appellants, with Pascua having previously warned that if they did not “get him” first, he would “get them.”

Defense Arguments

The appellants raised a two-pronged defense:

The alibi argument:

Appellant Balacio claimed that he was at the Asin Hot Spring celebrating New Year with companions, including appellant Bisaya, Elmos Lingbanan, and Wilson Ducay.
Appellant Bisaya corroborated this by stating that he, along with his co-accused, spent the entire night at the Asin Hot Spring.

The challenge to the credibility of Iday’s testimony:

The appellants questioned whether Iday could clearly see the crime given he was about 120 feet away and argued that the trees would obstruct the view.
They described discrepancies in Iday's shadowing of their movements from the liquor store to the scene of the stabbing.

The trial court, after an ocular inspection of the crime scene, found that:

The illuminations from the street lamp, hotel bulb, and bonfire were sufficient to dispel the claimed visual obstructions.
The positive identification by Iday and the physical evidence conclusively linked the appellants to the crime.

The delay in Iday’s reporting to the authorities was attributed, in part, to a genuine fear for his life and that of his family, especially given the presence of strangers at his home following the incident.

Judicial Findings and Sentencing

The Regional Trial Court, Branch 8, La Trinidad, Benguet, found the appellants guilty beyond reasonable doubt of murder.
The original sentence imposed was reclusion perpetua.
The trial court also ordered:

Payment of civil indemnity for loss of support and moral damages.
Payment of costs.
Award of civil indemnity for the death of the victim was initially set at P30,000.00.

On appeal, this court increased the civil indemnity for the victim’s death to P50,000.00, in line with established jurisprudence (People v. Sison, 189 SCRA 700 [1990]).

Issues:

Whether the defense of alibi could exonerate the appellants given that their alleged presence at the Asin Hot Springs was not geographically or chronologically impossible to reconcile with committing the crime.

The defense posited that being at the hot springs precluded their presence at the scene during the crime.
The court examined whether the distance between the hot springs and the crime scene allowed sufficient time for the crime to be committed.

The credibility and reliability of the sole eyewitness testimony, particularly:

Whether Francisco Iday’s position, despite being 120 feet from the scene, allowed him to have a clear, unobstructed view of the events.
The defense’s argument regarding possible visual obstructions and inconsistencies in Iday’s account.

The sufficiency of the physical and circumstantial evidence in positively identifying the appellants as the perpetrators of the murder.

Ruling:

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Ratio:

(Subscriber-Only)

Doctrine:

(Subscriber-Only)

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Case Digest (G.R. No. L-16223-25) Core Legal Reasoning Model Expanded

Facts:

Case Digest (G.R. No. L-16223-25) Expanded Legal Reasoning Model

Facts:

Issues:

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Ratio:

Doctrine:

Case Digest (G.R. No. L-16223-25)
Core Legal Reasoning Model

Expanded

Case Digest (G.R. No. L-16223-25)
Expanded Legal Reasoning Model