Case Digest (G.R. No. 180986) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Mamerto Narvaez, decided April 20, 1983 under the 1973 Constitution, the accused, Mamerto Narvaez, was a long‐time settler in Maitum, South Cotabato, who built a house and rice mill on a parcel later claimed by Fleischer and Company. Despite pending litigation over the land, Narvaez executed a lease with the company in February 1967 but allegedly failed to pay rent. On June 25, 1968, the company’s secretary‐treasurer, Davis Q. Fleischer, terminated the lease and gave Narvaez until December 31 to vacate. On August 21–22, 1968, Fleischer, his assistant manager Flaviano Rubia, and laborers began erecting a fence that cut into Narvaez’s property, chiselling his wall and threatening to seal his door and rice mill from the highway. Awakened by the noise, Narvaez appealed to his compadre, Rubia, to stop and negotiate, but Fleischer retorted angrily, “Go ahead.” Thereupon Narvaez grabbed his shotgun, fatally shot Fleischer as he fell, then fired at Rubia Case Digest (G.R. No. 180986) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Land Dispute
- In 1937, Mamerto Narvaez and other Luzon settlers established residence and farms in Maitum, South Cotabato. They petitioned for subdivision of Celebes and Kalaong Plantations.
- Fleischer & Co. filed Sales Application No. 21983 (1,017.22 ha). A 1941 survey set 300 ha for the company and subdivided the remainder for settlers. Legal battles ensued:
- Civil Case No. 240 (1950) for annulment of award—dismissed in 1965 (CA G.R. No. 28858-R).
- Civil Case No. 755 (1966) likewise pending during the incident.
- To “avoid trouble,” appellant leased 100–140 m² of Lot 38 from the company in February 1967 but did not pay rent; company agents repeatedly demanded vacatur by December 31, 1968.
- The August 22, 1968 Incident
- While appellant rested in his highway-front house, Fleischer, Flaviano Rubia, and laborers began chiselling his walls and erecting a fence cutting off his access.
- Appellant appealed to stop and confer. Fleischer angrily ordered continuation. Appellant armed with a shotgun shot Fleischer (who fell) and then shot Rubia as he ran to a jeep’s firearm. Both died.
- Immediately thereafter, appellant voluntarily surrendered to police with the shotgun.
- Trial and Conviction
- The Court of First Instance of South Cotabato (Branch I) convicted appellant of murder qualified by treachery and aggravated by evident premeditation, mitigated by voluntary surrender, and imposed reclusion perpetua on each count plus P12,000 compensatory, P10,000 moral damages, P2,000 attorney’s fees per victim.
- Appellant appealed, claiming justification by defense of person and defense of rights.
Issues:
- Whether the killing was justified as self-defense or defense of rights (property).
- Whether the qualifying circumstances of treachery and evident premeditation were proven beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)