Case Digest (G.R. No. 237514) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Clemente John Lugod, G.R. No. 136253, decided on February 21, 2001 under the 1987 Constitution, the Regional Trial Court (RTC) of Santa Cruz, Laguna Branch 28 convicted Clemente John Lugod alias “Honasan” of rape with homicide for the abduction, sexual assault, and death of eight-year-old Nairube J. Ramos on or about September 16, 1997 in Cavinti, Laguna. An Information was filed on October 10, 1997, charging Lugod with forcible carnal knowledge and homicide to conceal the crime. During trial, the prosecution presented medical and lay witnesses who testified to the victim’s vulvar laceration, death from hypovolemic shock, and the discovery of the body in a grassy plantation. Witnesses also placed Lugod at various locations wearing a distinctive black T-shirt and rubber slippers. The police alleged that Lugod confessed and pointed out the body’s location without counsel. On Oc Case Digest (G.R. No. 237514) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charge and Arraignment
- On October 10, 1997, an Information for rape with homicide was filed against Clemente John Lugod for allegedly raping and killing eight-year-old Nairube J. Ramos in Cavinti, Laguna on September 16, 1997.
- Accused pleaded not guilty; trial commenced before the Regional Trial Court (RTC), Branch 28, Santa Cruz, Laguna.
- Prosecution Evidence
- Medico-legal Findings: Dr. Edilberto Castillo discovered an 8 cm vaginal laceration and ruled the cause of death as hypovolemic shock secondary to the laceration; cadaver was in advanced decomposition, death occurred approx. three days before his Sept. 19, 1997 examination.
- Clothing Identification: Violeta Cabuhat and Loreto Veloria testified that on the night of Sept. 15, 1997, Lugod wore a black collared T-shirt (Exh. E) and muddy rubber slippers with red soles and yellow straps (Exh. D).
- Early Morning Sighting: Tricycle driver Romualdo Ramos and Pedro Dela Torre saw Lugod, appearing drunk, exiting Villa Anastacia barefoot and without a T-shirt around 8:30–10:30 a.m. on Sept. 16, 1997.
- Discovery of Personal Effects: A search party led by Alma Diaz and Helen Ramos found the victim’s panty (Exh. F) and the same black T-shirt within Villa Anastacia; slippers matching Exh. D were found at the victim’s backdoor.
- Arrest, Statement and Pointing Out: SPO2 Quirino Gallardo arrested Lugod based on the slippers and T-shirt. He claimed Lugod confessed and later pointed out the body’s location by moving his lips in the presence of police and townspeople.
- Trial Court Decision
- On October 8, 1998, the RTC found Lugod guilty beyond reasonable doubt of rape with homicide under R.A. 7659, sentenced him to death, ordered P50,000 civil indemnity and P37,200 actual damages, plus costs.
Issues:
- Admissibility of Confession and Pointing Out
- Were Lugod’s uncounselled admission and his act of pointing out the body location admissible in evidence under the Constitution’s guarantee of the right to counsel and to remain silent (Art. III, Sec. 12)?
- Sufficiency of Circumstantial Evidence
- Did the circumstantial evidence presented—slippers, T-shirt, sightings—form an unbroken chain proving guilt beyond reasonable doubt and excluding all others?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)