Case Digest (G.R. No. 218702)
Facts:
In People of the Philippines v. Patrick John Mercado y Anticla, G.R. No. 218702, decided July 1, 2019 under the 1987 Constitution, the accused‐appellant Patrick John Mercado was charged with the murders of his aunt, Alicia Mercado-Lusuriaga, and her live‐in partner, Evelyn Santos, on October 15, 2007 in Sta. Maria, Bulacan. The Information alleged that Mercado, armed with a baseball bat and with intent to kill, struck both victims, poured gasoline on them, and set them and their house ablaze, causing third-degree burns that led to their instantaneous deaths. At trial, prosecution witnesses recounted the dying declarations of Evelyn—who, while mortally burned and bleeding, repeatedly identified Mercado as her assailant and arsonist. Mercado denied the charges, testifying that he was studying at home when the fire broke out and that he assisted Evelyn’s rescue; one neighbor avowed seeing an unidentified injured man escape the blaze. The Regional Trial Court of Malolos City, BranchCase Digest (G.R. No. 218702)
Facts:
- Parties and Charge
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Patrick John Mercado y Anticla
- Information: Double murder of Alicia Mercado-Lusuriaga and Evelyn Santos on October 15, 2007, by assault with a baseball bat and setting them on fire
- Prosecution’s Version
- Victims found burning; rescued but severely injured; Evelyn had third-degree burns (74% BSA) and head wounds
- Multiple witnesses heard dying declarations by Evelyn blaming Mercado for the assault and arson; she repeated the accusations en route to hospital
- Evelyn later died (Nov. 2, 2007); statements admitted as dying declarations and res gestae
- Defense’s Version
- Mercado claimed he was studying; fire broke out unexpectedly; he assisted victims and summoned help
- Eyewitness Dan Dacallos saw a bloodied stranger escape and Mercado throwing water; defense asserted reasonable doubt
- Procedural History
- RTC (Branch 78, Malolos) convicted Mercado of Double Murder (Feb. 24, 2012): reclusion perpetua; damages awarded
- CA (Second Division) affirmed conviction (June 20, 2014), modified penalty to two counts of reclusion perpetua
- Supreme Court appeal filed; decision promulgated Oct. 17, 2018
Issues:
- Whether the prosecution proved Mercado’s guilt beyond reasonable doubt
- Whether the use of fire qualifies the offense as murder under Art. 248 RPC
- Whether the mitigating circumstance of voluntary surrender applies
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)