Case Digest (G.R. No. 127755) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Joselito del Rosario y Pascual (G.R. No. 127755, April 14, 1999), the accused-appellant Joselito del Rosario, a tricycle driver in Cabanatuan City, was charged with the special complex crime of Robbery with Homicide together with Ernesto “Jun” Marquez, Virgilio “Boy” Santos, and John Doe alias “Dodong” Bisaya. On May 13, 1996, between 6:00 and 6:30 p.m., tricycle driver Paul Vincent Alonzo witnessed two men and a woman wrest a bag containing P200,000 in cash and jewelry from 66-year-old Virginia Bernas on General Luna Street. One of the men, armed with a gun, chased the victim’s helper, returned, and shot Bernas in the head. The robbers loaded the loot into a tricycle driven by del Rosario and fled to Brgy. Dicarma, where an armed encounter ensued and Marquez was killed. At trial in the Regional Trial Court of Cabanatuan City, del Rosario pleaded not guilty but was found guilty as co-principal and sentenced to death, plus payment of actual and mo Case Digest (G.R. No. 127755) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Charge
- Accused-appellant Joselito del Rosario y Pascual, together with Ernesto “Jun” Marquez, Virgilio “Boy” Santos, and John Doe “Dodong” Bisaya, was charged with the special complex crime of Robbery with Homicide for allegedly robbing 66-year-old Virginia Bernas of ₱200,000 in cash and jewelry and killing her.
- Only del Rosario was tried: Marquez was killed in a police encounter; Santos and “Dodong” remain at large.
- Commission of the Crime
- On May 13, 1996, between 6:00 and 6:30 p.m., tricycle driver Paul Alonzo witnessed at General Luna St., Cabanatuan City: two men and a woman grappling for a bag, one man armed with a gun chasing the victim’s helper, then returning to shoot the victim in the head.
- The gunman and his companion delivered the bag to a passenger inside del Rosario’s tricycle and fled; Alonzo noted the plate number and reported the incident to police.
- Accused’s Account
- Del Rosario admitted he was hired by Santos to drive and fetch Marquez and Bisaya, but claimed he had no prior knowledge of any robbery plan.
- At the scene, he tried to escape but was prevented by Santos, who threatened him with a gun; thereafter he was forced to drive the co-accused away and warned not to report the crime.
- Lower Court Proceedings
- The Regional Trial Court convicted del Rosario as co-principal in Robbery with Homicide, imposed the death penalty, and awarded damages to the victim’s heirs.
- On automatic review, del Rosario challenged the conviction on grounds of duress, lack of conspiracy, violation of constitutional rights during custodial investigation, and unlawful warrantless arrest.
Issues:
- Duress Defense
- Whether del Rosario acted under compulsion of an irresistible force that exempts him from criminal liability under Article 12(5), Revised Penal Code.
- Conspiracy Requirement
- Whether the prosecution proved beyond reasonable doubt an agreement (conspiracy) between del Rosario and his co-accused to commit robbery with homicide.
- Constitutional Rights
- Whether del Rosario’s rights to remain silent and to counsel during custodial investigation under RA 7438 and the Bill of Rights were violated, rendering his admissions inadmissible.
- Warrantless Arrest
- Whether del Rosario’s warrantless arrest complied with Section 5, Rule 113, of the Rules of Court, and if not, whether such illegality affects the trial court’s jurisdiction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)