Case Digest (G.R. No. 116239) Core Legal Reasoning Model
Facts:
On February 9, 1994, in Pasig, Metro Manila, SPO2 Elpidio Mercado y Hernando and SPO1 Aurelio Acebron y Adora, members of the Philippine National Police, forcibly abducted seventeen-year-old Richard Buama at gunpoint while he was with schoolmates Florencio Villareal and Eric Ona. Accused-appellants drove the youths to an apartment in Tanay, Rizal, where they brutally beat, stripped, blindfolded and gagged Richard, bound his limbs with rattan rope, and placed him in the luggage compartment of Mercado’s car. Two hours later, Mercado and Acebron returned without the victim, admitting they had “silenced” him and threatening Florencio and Eric into silence. On February 12, Richard’s body—bearing multiple lacerations, tied limbs, and intracranial hemorrhage from skull fracture—was retrieved from a morgue in Morong, Rizal. At the Regional Trial Court of Pasig (Branch 156), the court found the accused guilty of kidnapping with murder under Article 267 of the Revised Penal Code, as amen
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Case Digest (G.R. No. 116239) Expanded Legal Reasoning Model
Facts:
- Case Background
- Accused-appellants Elpidio Mercado (SPO2) and Aurelio Acebron (SPO1), members of the PNP, were charged with kidnapping with murder before RTC Branch 156, Pasig.
- The RTC found them guilty and sentenced each to death, P50,000 civil indemnity, P52,680 burial expenses, P100,000 moral/exemplary damages, and costs.
- Incident Chronology
- On February 9, 1994 at around 9 PM in Pasig, Mercado, armed and in police uniform, and his aide Eric Ona forcibly took 12-year-old Florencio Villareal and 17-year-old Richard Buama—suspected of stealing from Mercado’s video store—into Mercado’s red car.
- They were driven to a safe‐house apartment in Tanay, Rizal. There, the victim Richard was beaten, his hands and feet tied with rattan rope, gagged, stripped, and loaded into the car’s luggage compartment; Florencio and Eric were left behind under threat.
- After about two hours, Mercado and Acebron returned without Richard. When asked, they said he had been “silenced” or “laid to rest.” They then threatened Florencio and Eric at a beerhouse.
- On February 12, Virgilio Buama, Richard’s brother and a policeman, recovered Richard’s body from a morgue near Laguna. Postmortem showed intracranial hemorrhage from skull fracture, multiple lacerations, and bound limbs.
- Investigation by SPO2 James Mabalot: Florencio and Eric identified Mercado and Acebron from police photos; the car bore bloodstains consistent with the crime.
- Defense Case
- Accused-appellants pleaded alibi, presenting Tanay PNP logbooks and testimony of SPO4 Teofilo Paz Bias that they were on official duty in Tanay on February 9, signing logbooks at formation assemblies.
- Both accused testified to lengthy police/military careers, their duty roster in Tanay, and prior grievances with the witnesses, claiming false implication.
Issues:
- Whether R.A. No. 7659 (death penalty law) is constitutional under the 1987 Constitution and international obligations.
- Whether the trial court correctly assessed the credibility of principal witnesses Florencio Villareal and Eric Ona despite alleged inconsistencies.
- Whether the evidence—much of it circumstantial—was sufficient to prove kidnapping with murder beyond reasonable doubt.
- Whether there was a conspiracy between Mercado and Acebron to commit the crime.
- Whether the alibi defense based on logbooks and official assignments was valid.
- Whether the penalties and awards of damages were properly imposed and calculated.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)