Case Digest (G.R. No. 235787) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People v. Manzanilla y De Asis, G.R. No. 235787, decided June 8, 2020, the accused‐appellant, Florenda Manzanilla y De Asis, was charged with parricide under Article 246 of the Revised Penal Code for allegedly conspiring with Roberto Gacuma y Cabreana (deceased during trial) and an unidentified male accomplice to kill her husband, Angel Manzanilla y Saporma, on April 15, 2007 in Antipolo City. The Information alleged that appellant induced Roberto to shoot the victim in the head, causing instantaneous death. Arraigned in May 2012, appellant pleaded not guilty and went to trial before the Regional Trial Court (RTC) of Antipolo City, Branch 72. Prosecution witnesses—Hermie Manzanilla (victim’s brother), eyewitnesses Mark Lawrence Sarmenta and Ajie Bryle Balandres, and medico‐legal officer Dr. Jose Arnel Marquez—testified to appellant’s presence at the scene, her utterance of inciting words (“yariin na,” “bilis‐bilisan baka may makakita”), and the fatal gunshot wound. Appellant Case Digest (G.R. No. 235787) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charge and Arraignment
- On April 15, 2007, an Information for Parricide (Art. 246, RPC) was filed against Florenda Manzanilla y De Asis and co-accused Roberto Gacuma y Cabreana, alleging conspiracy to kill the victim, Angel Manzanilla y Saporma.
- Accused-appellant and Roberto pleaded not guilty upon arraignment on May 12, 2012; Roberto died November 18, 2010, and his case was dismissed.
- Prosecution’s Version
- Witnesses Mac-Mac Sarmenta and Ajie Balandres testified they saw the accused-appellant and an unidentified male companion waiting for the victim on a well-lit road in Antipolo City; accused-appellant was heard urging haste (“bilis-bilisan baka may makakita,” “yariin na”).
- Roberto approached the victim, led him to a darker spot, and shot him in the head; the victim died instantaneously (Dr. Marquez’s autopsy report).
- Defense’s Version
- Accused-appellant claimed alibi: she was at home and her store in Sto. Niño, Sta. Cruz, Antipolo City, with her son Angelo and neighborhood children, when the crime occurred.
- She denied knowing Roberto or participating in her husband’s death and presented no corroborating witnesses.
- Lower Courts’ Decisions
- The Regional Trial Court of Antipolo City convicted accused-appellant as principal by inducement of parricide and sentenced her to reclusion perpetua, with P50,000 civil indemnity and P25,000 exemplary damages.
- The Court of Appeals affirmed, increasing civil indemnity to P100,000, moral damages to P100,000, and exemplary damages to P100,000.
- Supreme Court Proceedings
- The Supreme Court granted review under Rule 124, Section 13(c), RTC-G.R. CR-HC No. 08336; issues raised concern liability as principal by inducement/conspiracy and proper penalties/damages.
- The Court admitted the prosecution’s evidence, weighed witness credibility, and received memoranda on applicable RPC provisions and jurisprudence on parricide, principal liability, and damage awards.
Issues:
- Whether the evidence establishes accused-appellant’s guilt for parricide as a principal by inducement or by conspiracy.
- Whether the penalty of reclusion perpetua and the awards for civil indemnity, moral, exemplary, and temperate damages are proper.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)