Case Digest (G.R. No. 203986) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Francisco Juan Larraaga alias “Paco,” et al. (G.R. Nos. 138874-75, February 3, 2004), the Regional Trial Court of Cebu City, Branch 7 convicted eight private individuals—Francisco Juan Larraaga alias Paco; Josman Aznar; Rowen Adlawan alias Wesley; Alberto CaAo alias Allan Pahak; Ariel Balansag; James Anthony Uy alias Wangwang; James Andrew Uy alias MM; and co-accused Davidson Valiente Rusia alias Tisoy Tagalog—of kidnapping and serious illegal detention in Criminal Cases Nos. CBU-45303 and CBU-45304 for abducting sisters Marijoy and Jacqueline Chiong on the night of July 16, 1997 in Cebu City. The sisters were forcibly handcuffed, gagged, driven in a convoy of a white car, red car and hired van to a “safehouse” in Guadalupe and ultimately to a ravine in Tan-awan, Carcar where Marijoy was gang-raped, beaten, thrown into a 150-meter ravine and left to die; Jacqueline was raped, dropped wounded, chased by her captors and disappeared thereafter. Trial Case Digest (G.R. No. 203986) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Victims: Sisters Marijoy (college beauty queen) and Jacqueline Chiong, residents of Cebu City.
- Accused/Appellants: Francisco Juan Larrañaaga (alias “Paco”), Rowen Adlawan (alias “Wesley”), Josman Aznar, Alberto CaAo (alias “Allan Pahak”), Ariel Balansag, James Anthony Uy (alias “Wangwang”), James Andrew Uy (alias “MM”), and Davidson Valiente Rusia (alias “Tisoy Tagalog,” later state witness).
- Chronology of the Crime
- July 16, 1997, ~10:30 PM at Ayala Center, Cebu City: Rowen and Josman forced Marijoy and Jacqueline into a white car, beat, handcuffed, and taped their mouths; group convoyed in white car and red car to a safehouse in Guadalupe.
- In safehouse: Marijoy and Jacqueline forcibly detained in separate rooms; limited supervision by Rusia; group then hired a white van (driver: Alberto; conductor: Ariel).
- Transfer to Tan-awan, Carcar: victims paraded, Jacqueline tortured and raped by multiple assailants; Marijoy repeatedly gang-raped, then at Josman’s order Rowen and Ariel shoved her off a 150 m cliff to her death; Jacqueline assaulted again and left missing.
- Procedural History
- Informations (Fourth Amended) filed May 12, 1998 (Criminal Cases CBU-45303: kidnapping with rape and homicide; CBU-45304: kidnapping and illegal detention). All accused pleaded not guilty; Larrañaaga refused to plead and was entered as not guilty.
- Prosecution: main witness Rusia (direct testimony Aug–Oct 1998), corroborated by 21 witnesses including eyewitnesses and forensic experts.
- Defense: alibi and denial; 19 witnesses (classmates, friends, airline personnel, neighbors, mechanic) to prove non-presence; numerous counsel withdrawals and appointment of P.A.O. counsel under continuous-trial order.
- Trial Court Decision (May 5, 1999): conviction of all appellants for kidnapping and serious illegal detention; penalty of two reclusiones perpetua each; indemnity P200,000 and moral/exemplary damages P5,000,000 jointly and severally.
Issues:
- Whether appellants’ due process rights were violated (choice of counsel, confrontation and cross-examination, presentation of evidence, impartial trial).
- Whether the trial court erred in discharging Davidson Rusia as an accused and admitting him as a state witness.
- Whether the prosecution evidence was insufficient or unreliable, and whether the defense of alibi was established.
- Whether the trial court improperly admitted or excluded evidence, displayed bias, and erred in finding conspiracy.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)