Case Digest (G.R. No. 133064) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On the night of January 9, 1966 in Iloilo City, Elias Jaranilla, Ricardo Suyo, and Franco Brillantes hailed a Ford pickup driven by Heman Gorriceta, ostensibly to fetch an item from Mandurriao. Upon arrival near the provincial hospital, the trio alighted and shortly reappeared carrying six fighting cocks stolen from a coop belonging to Valentin Baylon. As they fled toward Jaro district, they were intercepted on a detour road by Patrolmen Ramonito Jabatan and Benjamin Castro. When Jabatan ordered them down, Jaranilla fired and mortally wounded the officer. Gorriceta, frightened, drove the assailants home; they hid until surrender the next morning. A state witness, Gorriceta testified against his companions, while neighbor Victorino Trespeces corroborated the pursuit. An autopsy by Dr. Raymundo Torres confirmed a fatal bullet wound to Jabatan. Baylon identified the missing cocks, valued at ₱100 each. The three were charged with robo con homicidio aggravated by use of a motor vehic Case Digest (G.R. No. 133064) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Incident and prosecution
- On January 9, 1966 at around 11 p.m., Heman Gorriceta was driving his sister’s Ford pickup when he picked up Elias Jaranilla, Ricardo Suyo and Franco Brillantes on J.M. Basa Street, Iloilo City.
- They rode to Mandurriao. Near the provincial hospital, the three men alighted, returned after 10–20 minutes each carrying two fighting cocks, and directed Gorriceta to flee.
- While escaping toward Jaro, Patrolmen Ramonito Jabatan and Benjamin Castro gave chase. Jabatan fired a warning shot and signaled the truck to stop; the occupants did not comply. Jaranilla then shot Jabatan. Gorriceta panicked, drove them to La Paz, and hid the truck.
- Evidence presented
- Witness Victorino Trespeces saw three men with roosters near Valentin Baylon’s coop, alerted the police, pursued the truck by car, heard gunshots and aided the wounded Jabatan.
- Dr. Raymundo Torres’s autopsy: a bullet perforated Jabatan’s left lung and pulmonary artery, causing fatal hemorrhage.
- Baylon discovered his coop broken and six roosters taken (valued at ₱100 each); one was later recovered and identified.
- Procedural posture
- The Court of First Instance convicted Jaranilla, Suyo and Brillantes of robbery with homicide, sentenced each to reclusion perpetua, and awarded damages to Jabatan’s heirs and Baylon. Gorriceta was granted immunity as state witness.
- Before sentence promulgation, Jaranilla escaped; only Suyo and Brillantes received notice of judgment and filed appeals.
Issues:
- Procedural
- Whether Jaranilla’s appeal is valid despite his escape and the lack of formal promulgation.
- Whether only Suyo and Brillantes may properly appeal.
- Factual determination
- Who actually drove the truck and who shot Patrolman Jabatan?
- Legal characterization
- Whether the taking of the six roosters constituted robbery under Articles 294, 299 or 302 of the Revised Penal Code or was merely theft.
- Whether the homicide is “by reason or on the occasion of” the taking to qualify as robbery with homicide (Art. 294, RPC).
- Whether Suyo and Brillantes are criminally responsible as co-principals for the shooting.
- Sentencing and liability
- Appropriate penalty for the taking of six roosters.
- Proper adjudication of Jaranilla’s liability for both theft and homicide.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)