Case Digest (G.R. No. 209342) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On the evening of June 22, 2000, at the Caltex gasoline station in Tayuman, Binangonan, Rizal, armed men held up station employees and customers, fatally shooting Felix V. Regencia, Alexander C. Diaz, and Byron G. Dimatulac during the robbery of approximately ₱5,000 and several cans of oil. Initially, only George Marciales and Orly Nabia were arrested, tried, and convicted with their co-conspirators Paul Pobre and an alias “Jun,” with the charges against Pobre archived pending his apprehension. On July 2, 2006, the Philippine National Police arrested Crisente PepaAo NuAez under the belief that he was “Paul Pobre.” Despite his motion to dismiss for misidentification, the trial court denied it, amended the Information to name NuAez, and adopted evidence from the earlier trial of Marciales and Nabia while recalling two eyewitnesses—Ronalyn Cruz and Relen Perez—who positively identified NuAez as the fourth robber. NuAez testified that he was at his aunt’s fish store in Muzon, Taytay Case Digest (G.R. No. 209342) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Crime and Initial Proceedings
- On June 22, 2000, four armed men—George Marciales, Orly Nabia, “Paul Pobre,” and “Jun”—robbed the Caltex station in Binangonan, Rizal, taking ₱5,000 and oil cans, and fatally shooting employees Felix V. Regencia, Alexander C. Diaz, and Byron G. Dimatulac.
- Marciales and Nabia were arrested first, tried in 2005, convicted of robbery with homicide, and sentenced to death; the case against Pobre and Jun was archived pending arrest.
- Arrest and Trial of Crisente PepaAo NuAez
- On July 2, 2006, police apprehended Nuaez as “Paul Pobre,” denying his motion to dismiss for mistaken identity; the Information was amended to name him.
- Prosecution adopted evidence from the earlier trial and recalled eyewitnesses Ronalyn Cruz and Relen Perez, who positively identified Nuaez as a shooter.
- Nuaez testified to a fish-store alibi and claimed wrongful arrest and mistaken identity.
- Decisions Below
- February 24, 2010 RRTC Decision: convicted Nuaez of robbery with homicide, sentenced him to reclusion perpetua plus damages for funeral expenses, death indemnity, exemplary damages, and unearned income.
- June 26, 2013 CA Decision: affirmed conviction, modified awards of moral and exemplary damages; Nuaez filed appeal to the Supreme Court.
- Supreme Court docketed appeal (Oct 22, 2013); parties declined supplemental briefs.
Issues:
- Whether the prosecution proved beyond reasonable doubt that Crisente PepaAo NuAez is the same person earlier referred to as “Paul Pobre” who conspired to commit robbery with homicide.
- Whether the eyewitness identifications of Nuaez by Cruz and Perez were sufficiently reliable under the totality of circumstances.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)