Case Digest (G.R. No. 115217) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Leonardo Macalindong y Andallon, the Plaintiff-Appellee is the People of the Philippines and the Accused-Appellant is Leonardo Macalindong y Andallon. On February 10, 2007 at around 8:00 PM in Sitio Riverside, Barangay Pakyas, Municipality of Victoria, Oriental Mindoro, Macalindong allegedly stabbed his live-in partner, Jovelia Malinao y Panot, with a knife causing her instantaneous death. The Information charged him with murder under Article 248 of the Revised Penal Code, citing treachery, evident premeditation, and abuse of superior strength as qualifying circumstances. During the trial in the Regional Trial Court (RTC), Branch 40, Calapan City, the prosecution’s key witness was the couple’s seven-year-old daughter, Lyn Joy, who positively identified her father as the assailant and testified that she saw him stab her mother twenty-two times. The prosecution also presented a police blotter entry, crime-scene photographs, and the medico-legal cert Case Digest (G.R. No. 115217) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Case Background
- Appellant was charged on February 10, 2007, with the murder of his live-in partner, Jovelia Malinao, in Oriental Mindoro, allegedly committed with treachery, evident premeditation, and abuse of superior strength.
- At arraignment before RTC Branch 40, Calapan City, appellant pleaded not guilty and asserted a defense of mental incapacity (schizophrenia).
- Trial Proceedings
- Prosecution Evidence
- Seven-year-old daughter Lyn Joy positively identified her father as the person who stabbed her mother 22 times with a knife.
- Stipulated police blotter entries, crime scene photographs, knife identification, and Dr. Valdez’s autopsy findings and death certificate.
- Defense Evidence
- Appellant testified he “blacked out” and was unsure if he killed Jovelia.
- Introduced a Medical Certificate (Nov. 9, 2007) and an NCMH Initial Report (Mar. 10, 2008) diagnosing schizophrenia; no psychiatric expert testified.
- Lower Courts’ Rulings
- RTC Decision (Dec. 10, 2015)
- Convicted appellant of murder with the qualifying circumstance of treachery.
- Imposed reclusion perpetua; awarded ₱100,000 civil indemnity, ₱75,000 moral damages, ₱50,000 exemplary damages.
- CA Decision (Apr. 4, 2019)
- Affirmed with modification: added abuse of superior strength as qualifier.
- Increased moral and exemplary damages to ₱100,000 each; ordered 6% interest per annum from Information filing and from finality.
Issues:
- Can appellant invoke the insanity exemption under RPC Article 12?
- Was appellant properly convicted of murder, or should the offense be classified as homicide?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)