Case Digest (G.R. No. 109713) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The People of the Philippine Islands vs. Lol-lo and Saraw, decided February 27, 1922, the appellants Lol-lo and Saraw—both Moros residing in South Ubian, Tawi-Tawi, Sulu—were charged in the Court of First Instance of Sulu with the crime of piracy. On or about June 30, 1920, two small vessels carrying eleven Dutch subjects left Matuta bound for Peta. Near the islands of Buang and Bukid, six armed Moro vintas commanded by twenty-four men surrounded and boarded the second vessel under the pretext of seeking food. Once aboard, they seized thirty-nine sacks of copra, assaulted several men, and brutally violated two women. The pirates then punched holes in the vessel to drown its occupants, abandoned them at sea, and carried the two women captive to Maruro, where they again raped them. After the women escaped, Lol-lo and Saraw fled to South Ubian, where they were arrested. Their demurrer to the indictment was overruled, and upon trial they were convicted and each sentenced to caden Case Digest (G.R. No. 109713) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Initial Voyage and Attack
- On or about June 30, 1920, two boats carrying Dutch subjects departed Matuta for Peta in the Dutch East Indies.
- At around 7 p.m., near the Islands of Buang and Bukid, six Moros in six vintas armed with firearms surrounded the second boat.
- Pirate Conduct and Victim Treatment
- The Moros boarded, demanded food, then forcibly seized all cargo, attacked male passengers, and brutally violated two young women.
- The remaining passengers were placed back in the boat after holes were bored to sink it; they endured eleven days adrift until rescued. The two women were taken aboard and repeatedly raped, escaping at Maruro.
- Arrest and Prosecution
- Defendants Lol-lo and Saraw returned to South Ubian, Tawi-Tawi, where they were arrested and charged with piracy in the Court of First Instance of Sulu.
- Their counsel filed a demurrer contesting jurisdiction and the existence of a public offense; the trial court overruled it, convicted both, and imposed life imprisonment, restitution of 924 rupees, and half the costs.
Issues:
- Jurisdiction
- Whether the Court of First Instance of Sulu had jurisdiction to try acts of piracy committed beyond Philippine territorial waters.
- Applicability of the Spanish Penal Code
- Whether Articles 153–156 of the Spanish Penal Code on piracy remained in force in the Philippines after cession to the United States.
- Whether those provisions could be applied with appropriate substitution of terms (“United States” for “Spain,” “citizens of the United States and citizens of the Philippine Islands” for “Spaniards”).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)