Case Digest (G.R. No. 138874-75) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Francisco Juan LarraAaga alias “Paco,” Josman Aznar, Rowen Adlawan alias “Wesley,” Albert CaAo alias “Allan Pahak,” Ariel Balansag, James Anthony Uy alias “Wangwang,” and James Andrew Uy alias “MM” (G.R. Nos. 138874–75, July 21, 2005), the Supreme Court En Banc resolved four separate motions for reconsideration filed after its February 3, 2004 Decision. In that Decision, the Court affirmed the Regional Trial Court, Branch 7, Cebu City’s convictions in Criminal Cases Nos. CBU-45303 and CBU-45304 for the special complex crime of kidnapping and serious illegal detention with homicide and rape (punishable by death under R.A. 7659) and simple kidnapping and serious illegal detention (punishable by reclusion perpetua or prision mayor). It imposed the death penalty on LarraAaga, Aznar, Adlawan, CaAo, Balansag, and James Andrew Uy; reclusion perpetua on James Anthony Uy for homicide and rape; prision mayor to reclusion temporal on James Anthony Uy for si Case Digest (G.R. No. 138874-75) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Case Background
- Appellants Francisco Juan LarraAaga et al. were charged with the special complex crime of kidnapping and serious illegal detention with homicide and rape (Criminal Case No. CBU-45303) and the crime of simple kidnapping and serious illegal detention (Criminal Case No. CBU-45304) before the Regional Trial Court, Branch 7, Cebu City.
- By Decision dated February 3, 2004, the Supreme Court affirmed the RTC convictions with modifications: imposition of the death penalty on most appellants in CBU-45303, reclusion perpetua in CBU-45304, and varying penalties for the minor appellant James Anthony Uy, together with joint and several civil liabilities.
- Motions for Reconsideration
- Four separate motions were filed by (a) LarraAaga, (b) Josman Aznar, (c) Rowen Adlawan, Alberto CaAo and Ariel Balansag, and (d) James Anthony Uy and James Andrew Uy, reasserting arguments on alibi, planting of evidence, exclusion of defense witnesses, identity of the corpse, and due process violations.
- Supplemental submissions included (a) a forensic study by Dr. Racquel Del Rosario-Fortun and (b) an affidavit by Atty. Florencio Villarin, Regional Director of the NBI Central Visayas, contesting the police investigation and witness credibility.
- Supreme Court Proceedings
- The Solicitor General filed consolidated comments opposing all motions, describing them as mere reiterations of previously rejected arguments.
- Appellants filed replies and rejoinders; the Supreme Court treated most grounds as rehash and addressed only the bona fides of James Andrew Uy’s claim of minority.
Issues:
- Whether the testimony of prosecution witness David Rusia was credible and sufficiently corroborated.
- Whether appellants’ alibi defense satisfied the requirements of time and place and was entitled to greater weight than positive identifications.
- Whether the trial court violated due process by excluding defense witnesses Professor Jerome Bailen and Atty. Florencio Villarin.
- Whether the body found in Tan-awan, Carcar was conclusively that of Marijoy Chiong.
- Whether James Andrew Uy was a minor at the time of the offenses, necessitating penalty reduction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)