Case Digest (G.R. No. 215720) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Oscar Mat-An y Escad, the accused-appellant, Oscar Mat-An y Escad (Oscar), was charged on April 13, 2009 in the Regional Trial Court of Baguio City, Branch 59, with two crimes under two separate Informations: Attempted Homicide for allegedly stabbing his 18-month-old granddaughter Anthonette Ewangan on April 8, 2009, and Murder for stabbing his 61-year-old mother-in-law, Minda Babsa-ay, twice in the chest with a knife on the same day. The two cases were consolidated on May 13, 2009. Oscar pleaded not guilty at arraignment on June 2, 2009 and underwent pre-trial on November 10, 2009. The prosecution presented ten witnesses, including bystanders and medical experts, who testified that Oscar entered Minda’s store while she held Anthonette, argued with Minda, and then stabbed her to death, also wounding the child. Forensic evidence established multiple fatal stab wounds on Minda and a superficial wound on Anthonette. The defense offered Oscar’s denia... Case Digest (G.R. No. 215720) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charging and Procedural Background
- On 13 April 2009, Oscar Mat-An y Escad was charged by two Informations before the Regional Trial Court (RTC) of Baguio City:
- Criminal Case No. 29335-R for Attempted Homicide of 18-month-old Anthonette Ewangan (Article 266, RPC).
- Criminal Case No. 29336-R for Murder of 61-year-old Minda Babsa-ay (Article 248, RPC), with aggravating circumstances of evident premeditation and abuse of superior strength.
- On 13 May 2009, the RTC granted a motion to consolidate the two cases. Oscar pleaded not guilty on 2 June 2009.
- Incident and Prosecution Evidence
- On 8 April 2009 at around 11:00 a.m., an argument erupted at Minda’s store in Baguio City when Oscar, reportedly intoxicated, confronted Minda about his wife’s remittances.
- Witnesses Norma Gulayan and Clyde Bunhian heard moans, saw Oscar stab Minda twice in the chest, and pulled him away; Norma called for help and sought Oscar’s daughter Sheyanne.
- Sheyanne Mat-an and neighbors, including PO1 Jose Mana-ar (on vacation), apprehended Oscar and turned over the knife.
- Dr. John Tinoyan’s autopsy revealed four chest stab wounds on Minda (three fatal); Dr. Samuel Daw-as found a superficial stab wound on Anthonette’s nape.
- Anthonette’s hospital bills amounted to ₱929.00; Minda’s wake and burial expenses amounted to ₱83,763.00 (admitted by defense).
- Defense Version
- Oscar testified that he had been drinking at a neighbor’s house, went to buy bread but “blacked out” after a brief exchange with Minda, and later found himself by the roadside awaiting a taxi.
- He denied any recollection of stabbing Minda or Anthonette and maintained surprise at his charges.
Issues:
- Whether the prosecution established beyond reasonable doubt the elements of murder of Minda Babsa-ay, notably evident premeditation or abuse of superior strength.
- Whether the prosecution proved Oscar’s intent to kill Anthonette Ewangan, supporting a conviction for attempted homicide rather than mere physical injury.
- Whether Oscar’s alleged intoxication should qualify as a mitigating circumstance.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)