Case Digest (G.R. No. L-568) Core Legal Reasoning Model
Facts:
In The People of the Philippines vs. Juan Francisco (78 Phil. 694, July 16, 1947, En Banc, G.R. No. L-568), the defendant-appellant Juan Francisco was detained for robbery in the municipal jail of Mansalay, Mindoro, when on March 4, 1945 he obtained permission from Chief of Police Alfredo Iwahi to visit his home and arrange bail. He was escorted by Sergeant Pacifico Pimentel, who remained at the foot of the stairs while Francisco spoke with his wife, Emilia Taladtad. Soon after, Pimentel heard a scream, rushed upstairs, and found Emilia bleeding from a wound in her right breast, Francisco wounded in the abdomen, and their one-and-a-half-year-old son, Romeo Francisco, fatally stabbed in the back. The child died shortly thereafter. On March 5, 1945, before the Justice of the Peace, Francisco signed Exhibit C, an extrajudicial affidavit confessing that, driven by shame and suicidal impulse, he stabbed his wife, then his son, then himself. Exhibit D records his arraignment and plea
Case Digest (G.R. No. L-568) Expanded Legal Reasoning Model
Facts:
- Pre-Arrest and Jail Supervision
- On March 4, 1945, Juan Francisco, detained for robbery in the municipal jail of Mansalay, Mindoro under Chief of Police Alfredo Iwahi, requested furlough to arrange bail.
- Sergeant Pacifico Pimentel was detailed to guard him and escorted him to his home.
- Parricide Incident at the Family Home
- Pimentel remained at the foot of the stairs while appellant met his wife, Emilia Taladtad, and their one-and-a-half-year-old son, Romeo Francisco, in an upstairs room.
- Shortly later Pimentel heard screams. He found the wife bleeding from a chest wound, the child fatally stabbed in the back, and appellant wounded in the abdomen. Romeo died immediately.
- Extrajudicial Confession and Arraignment
- On March 5, 1945, before the Justice of the Peace and witnesses, appellant signed Exhibit C confessing that, driven by shame after threats from his uncle and father-in-law, he grabbed a pair of scissors and stabbed his wife, child, and then himself.
- He was then arraigned (Exhibit D) and pleaded guilty; at trial before the Court of First Instance he recanted, alleging coercion by Sergeant Pimentel.
- Trial Proceedings
- The prosecution offered Exhibits C and D, testimony of Sgt. Pimentel, and rebuttal testimony of Emilia Taladtad.
- Defense challenged the voluntariness of Exhibit C and the competency of the wife’s testimony under Rule 123 § 26(d), and asserted a mitigating circumstance of moral illness under Article 13(9) of the Revised Penal Code.
- The trial court found the confession voluntary, the wife’s testimony admissible by waiver, no insanity, and convicted appellant of parricide, sentencing him to reclusion perpetua, civil indemnity of ₱2,000, and costs.
Issues:
- Validity of Extrajudicial Confession (Exhibit C)
- Was the confession made voluntarily, with full understanding and without coercion?
- Did alleged threats or mistreatment by Sergeant Pimentel invalidate it?
- Identification and Admissibility of Arraignment Record (Exhibit D)
- Was Exhibit D properly identified as the certified Justice of the Peace record?
- Is it admissible despite defense objections?
- Competency of Wife’s Rebuttal Testimony
- Does Rule 123 § 26(d) bar spousal testimony against appellant?
- Did appellant waive his wife’s incompetency by accusing her of the killing in his own testimony?
- Mitigating Circumstance under Article 13(9)
- Was appellant’s “moral illness” that diminished his will-power established?
- Does it reduce the penalty from death to reclusion perpetua pursuant to Article 63?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)