Case Digest (G.R. No. 91025) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People vs. Oanis and Galanta, G.R. No. 47722, decided July 27, 1943 under the 1935 Constitution, Antonio Z. Oanis (chief of police of Cabanatuan) and Corporal Alberto Galanta (Philippine Constabulary) were ordered by the Constabulary provincial inspector, Captain Monsod, to arrest fugitive lifer Anselmo Balagtas “dead or alive.” On December 24, 1938, they, accompanied by other soldiers, went to a house on Rizal Street where a bailarina named Irene was reported to be sheltering Balagtas. Guided by a neighbor, they found Serapio Tecson sleeping with his back to the door. Without prior identification or provocation, both defendants simultaneously or successively fired .32 and .45 caliber revolvers, killing Tecson. The lower court convicted them of homicide through reckless imprudence and sentenced each to one year and six months to two years and two months of prision correccional plus indemnity of ₱1,000. Both appealed.Issues:
- Did the appellants’ use of lethal force against a
Case Digest (G.R. No. 91025) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- G.R. No. 47722, decided July 27, 1943.
- Parties: The People of the Philippines vs. Antonio Z. Oanis (Chief of Police, Cabanatuan) and Alberto Galanta (Corporal, Philippine Constabulary).
- Events Leading to the Killing
- On December 24, 1938, Capt. Monsod (Constabulary Provincial Inspector) received a telegram from Manila ordering the capture, “dead or alive,” of escaped convict Anselmo Balagtas, with bailarina Irene.
- Monsod assembled Oanis, Galanta and three privates; showed them the telegram and Balagtas’s photo; instructed to arrest Balagtas and, if overpowered, follow the “dead or alive” order.
- The party went to Irene’s house. Oanis questioned Brigida Mallare about the room’s location and was told that Balagtas was sleeping there with Irene.
- Oanis and Galanta opened or fired through the door without further inquiry, striking and killing Serapio Tecson (Irene’s paramour), whom they mistook for Balagtas. Both admitted, “We two, sir,” had shot him. Autopsy revealed multiple .32 and .45 caliber gunshot wounds.
- Procedural History
- The trial court convicted both appellants of homicide through reckless imprudence; sentenced them to 1½ to 2 years and 2 months of prisión correccional and joint indemnity of ₱1,000 to the heirs.
- Both defendants appealed.
Issues:
- Classification of the Killing
- Can an honest mistake of fact in the performance of official duty exculpate the officers?
- Should the killing be classified as homicide through reckless imprudence or as murder?
- Applicability of Circumstances
- Does the qualifying circumstance of alevosía (attacking a sleeping victim) apply?
- Is there an incomplete justifying circumstance under Article 11(5) of the Revised Penal Code?
- What is the appropriate penalty under Article 69 of the Revised Penal Code?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)