Case Digest (G.R. No. 85043) Core Legal Reasoning Model
Facts:
In the case G.R. No. 85043, titled The People of the Philippines vs. Glenn Hatton, the accused-appellant Glenn Hatton was charged with the murder of Faustino Algarme. The incident occurred on August 29, 1986, around 7:30 PM in Catarman, Northern Samar during the town fiesta celebrations. According to the complaint filed by Police Corporal Jose C. Custorio, Hatton allegedly attacked Algarme with a knife known as 'Dipang,' showing intent to kill through treachery and evident premeditation, and ultimately inflicted a fatal stab wound upon the victim.
Upon his arraignment, Hatton pleaded not guilty and presented a defense of alibi, claiming to have been at the residence of his friend Eddie Laguitan during the time of the stabbing, corroborated by others present. The prosecution’s key witnesses included Edgardo Ongue and Romeo Basierto, who recounted witnessing the stabbing. Ongue noted he was struck by the assailant's mestizo features, whereas Basierto claimed he saw t
Case Digest (G.R. No. 85043) Expanded Legal Reasoning Model
Facts:
- Incident Details:
- On August 29, 1986, during the town fiesta of Catarman, Northern Samar, Faustino Algarme was stabbed and killed.
- The victim was walking with friends (Edgardo Ongue, Romeo Basierto, and Jesus Aboda) when they encountered two men, one tall and one short.
- The tall man tapped Algarme’s shoulder and stabbed him with a knife. The victim shouted for help and identified the assailant as "Romy" before collapsing.
- The assailant fled towards the house of Nonong Hatton, and the victim was taken to the hospital, where he died from the stab wound.
- Witness Testimonies:
- Edgardo Ongue: Witnessed the stabbing and described the assailant as tall with mestizo features. He later identified the accused, Glenn Hatton, at the police station after being shown a suspect.
- Romeo Basierto: Chased the assailant but initially did not recognize him. He later identified Hatton as the assailant during the trial.
- Both witnesses claimed to recognize Hatton as the assailant, but their identification was questioned due to inconsistencies and suggestive police procedures.
- Defense of Alibi:
- Glenn Hatton claimed he was at a friend’s house during the time of the incident, celebrating a baptism. His alibi was corroborated by witnesses, including Mrs. Laguitan and Jaime Mijares.
- Hatton also testified that he is left-handed, while the prosecution claimed the assailant used his right hand to stab the victim.
- Police Investigation:
- The police failed to conduct a proper line-up. Ongue identified Hatton after being pointed out by the police as the suspect.
- Basierto’s sworn statement did not initially name Hatton as the assailant, raising doubts about his identification.
- Trial Court Decision:
- The trial court convicted Hatton of murder, sentencing him to reclusion perpetua and ordering him to pay indemnity to the victim’s heirs.
- The court dismissed Hatton’s alibi and left-handedness as trivial details.
Issues:
- Whether the trial court violated Hatton’s right to due process by allegedly aligning itself with the prosecution.
- Whether the trial court erred in dismissing Hatton’s left-handedness as a trivial detail.
- Whether the identification of Hatton as the assailant was valid, given the lack of a proper police line-up and suggestive identification procedures.
- Whether the trial court erred in not crediting Hatton’s defense of alibi.
- Whether the prosecution proved Hatton’s guilt beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)