Case Digest (G.R. No. 130634-35) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Manolito Oyanib y Mendoza, G.R. Nos. 130634-35 decided on March 12, 2001 under the 1987 Constitution, the plaintiff-appellee is the People of the Philippines and the accused-appellant is Manolito Oyanib y Mendoza. On September 11, 1995, the Iligan City Prosecutor filed two informations in Regional Trial Court, Branch 02, Iligan City before Judge Maximo B. Ratunil, charging Oyanib with murder under Article 248 of the Revised Penal Code for stabbing Jesus Esquierdo to death and with parricide under Article 246 for killing his wife, Tita T. Oyanib, both on September 4, 1995 at Purok 3-A, Tambacan, Iligan City. After arraignment and a joint trial due to their common facts, evidence showed that the married couple had separated in 1994 and that on the charged night Oyanib surprised his wife and her paramour, Jesus, in the act of sexual intercourse. A scuffle ensued during which Oyanib stabbed them both, resulting in their deaths. He voluntarily surrende... Case Digest (G.R. No. 130634-35) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and charges
- Manolito Oyanib y Mendoza (accused-appellant) charged with:
- Criminal Case No. II-6012 – Murder of Jesus Esquierdo under Article 248 RPC with evident premeditation
- Criminal Case No. II-6018 – Parricide of his wife, Tita T. Oyanib, under Article 246 RPC with evident premeditation
- Informations filed on September 4, 1995; accused voluntarily surrendered and pleaded not guilty
- Marital background and separation
- Married since February 3, 1979, with two children; separated in 1994 due to marital differences
- Tita rented second‐floor room of Edgardo Lladas’s house; Manolito retained custody of children
- Events of September 4–5, 1995
- Evening of September 4: Manolito received school letter about son, went to Tita’s rented room, heard “sounds of romance,” pried door with knife, found Tita and Jesus in sexual act
- Accused stabbed Jesus multiple times after being kicked; Tita armed with broken bottle, stabbed Manolito in the arm; in ensuing rage Manolito stabbed Tita multiple times—both victims died
- Investigation and trial court proceedings
- Police blotter entry, recovery of the hunting knife, medico-legal examinations confirming fatal stab wounds
- Joint trial before RTC Branch 02, Iligan City; May 26, 1997 decision found accused guilty of homicide and parricide, imposed indeterminate sentence and reclusion perpetua, awarded civil indemnities
- Appeal filed June 17, 1997 to Supreme Court, invoking Article 247 RPC (exceptional circumstances)
Issues:
- Whether accused-appellant proved the essential elements of the exceptional circumstance under Article 247 RPC (surprising spouse in flagrante delicto, killing in the act or immediately thereafter, absence of consent to infidelity) by clear and convincing evidence
- Whether the trial court erred in denying exempting privilege under Article 247 RPC and in imposing the original penalties
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)