Case Digest (G.R. No. 125346) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Leo Echegaray y Pilo (G.R. No. 117472, en banc, February 7, 1997), the accused-appellant, Leo Echegaray, was tried by the Regional Trial Court of Pasay City for the April 1994 rape of his ten-year-old daughter. On conviction, the trial court imposed the death penalty pursuant to Republic Act No. 7659 (the “Death Penalty Law”), in force at the time of the offense. Upon automatic review, the Supreme Court, on June 25, 1996, affirmed both conviction and sentence. On July 9, 1996, Echegaray filed a Motion for Reconsideration challenging the victim’s grandmother’s alleged ill motive, and on August 23, 1996, his new counsel from FLAG submitted a Supplemental Motion raising seven grounds: (1) bar by pardon and affidavit of desistance; (2) vagueness of the charged date; (3) insufficient proof beyond reasonable doubt; (4) misidentification of paternal relationship; (5) trial-court bias and denial of due process; (6) ineffective assistance of former counse Case Digest (G.R. No. 125346) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Circumstances Leading to Conviction
- In April 1994, accused-appellant Leo Echegaray raped his ten-year-old daughter. Republic Act No. 7659 (Death Penalty Law) was already in effect, making death the mandatory penalty.
- On June 25, 1996, the Supreme Court, sitting en banc, affirmed his conviction and imposed the death sentence.
- Motions for Reconsideration
- First Motion (filed July 9, 1996) challenged the victim’s grandmother’s alleged sinister motive; it was denied.
- Change of Counsel (August 6, 1996) and Supplemental Motion (filed August 23, 1996) by FLAG raised seven grounds:
- Pardon/desistance by the offended party as a bar to prosecution
- Vagueness of the crime date in the complaint
- Insufficient proof beyond reasonable doubt
- Erroneous paternity finding
- Trial court bias and due-process violation
- Ineffective assistance of prior counsel
- Per se unconstitutionality of RA 7659 as cruel, degrading, excessive
Issues:
- Whether factual or legal matters not raised at trial or on direct appeal can be entertained on motion for reconsideration.
- Whether prior counsel’s performance amounted to gross incompetence warranting relief.
- Whether RA 7659 (Death Penalty Law) is unconstitutional under:
- Article III, Section 19(1) (cruel, degrading or inhuman punishment)
- Article III, Section 11 (excessive fines, cruel or unusual punishment)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)