Case Digest (G.R. No. 213943) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Marlon Delim, et al. (G.R. No. 142773, January 28, 2003), the Regional Trial Court of Urdaneta City, Branch 46, convicted appellants Marlon, Leon and Ronald Delim—uncles and nephews of the victim respectively—for the murder of Modesto Delim. On January 23, 1999 at around 6:30 PM in Barangay Bila, Sison, Pangasinan, three armed men (later identified as Marlon, Robert [at large] and Ronald) forcibly entered the victim’s home, threatened him with handguns, hog-tied and gagged him, then dragged him outside. Two other relatives (Leon and Manuel [at large]) stood guard at the door to prevent interference by the victim’s wife, Rita, and their 16-year-old son, Randy. The victim’s body was recovered decomposed under bushes in Paldit, some 200 meters from his home, on January 27, 1999. Autopsy revealed five gunshot wounds to the head, multiple stab wounds (including defensive wounds) and signs of putrefaction. Rita and Randy positively identified the three Case Digest (G.R. No. 213943) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- On May 4, 1999, an Information was filed charging Marlon Delim, Leon Delim, Manuel Delim (alias aBonga), Robert Delim, and Ronald Delim (alias aBonga) with murder under Article 248, RPC as amended by R.A. 7659. Only Marlon, Leon, and Ronald were apprehended; Manuel and Robert remained at large.
- At arraignment, Marlon, Leon, and Ronald pleaded not guilty. The Regional Trial Court (RTC), Branch 46, Urdaneta City, convicted them of aggravated murder on January 14, 2000, sentencing each to death and ordering joint and several damages of ₱75,000 (moral) and ₱25,000 (exemplary).
- Circumstances of the Abduction and Death
- On January 23, 1999 at around 6:30 PM in Brgy. Bila, Sison, Pangasinan, three armed men—identified by witnesses as Marlon, Robert, and Ronald—barged into the home of carpenter Modesto Delim, who was dining with his wife Rita and 16-year-old son Randy. They hog-tied and gagged Modesto; two others, Manuel and Leon, stood guard at the door.
- Modesto was led away; Manuel and Leon remained until about 7:00 AM the next day. The family refrained from seeking help. Randy and relatives searched repeatedly; on January 27, 1999 at about 3:00 PM they found Modesto’s decomposing cadaver under bushes 200 m from the house.
- Evidence Presented and Defense
- Prosecution witnesses Rita and Randy identified the three intruders by name and role; autopsy by Dr. De Guzman showed five gunshot wounds (all fatal) and seven defensive stab wounds; police confirmed all five had unlicensed firearms; the three accused had pending criminal cases and fled upon learning of the investigation.
- The accused invoked alibi: Ronald claimed he was home in Asan Norte with family; Leon testified he lived and worked in Laoag City since 1997; Marlon alleged he was on vacation in Dumaguete City until January 29, 1999. They denied involvement and blamed mistaken identity or ulterior political motives.
Issues:
- Nature of the Offense
- Whether the Information charged aggravated murder under Article 248 or kidnapping under Article 267.
- Sufficiency of Evidence
- Whether the prosecution proved beyond reasonable doubt the elements of the crime charged and each accused’s participation (corpus delicti and identity).
- Credibility of Defenses
- Whether the alibi defenses were sufficiently established to raise reasonable doubt.
- Qualifying and Aggravating Circumstances and Penalty
- Whether treachery, abuse of superior strength, nighttime, dwelling, and use of unlicensed firearms were properly alleged and proved to warrant the death penalty or a lesser penalty.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)