Title
People vs. Padal, Jr.
Case
G.R. No. 232070
Decision Date
Oct 2, 2019
Ragnel Laguardia was killed in Davao City in 2007; Romeo and Reynan Padal, identified by witnesses, were convicted of murder, with the use of a motorcycle as a qualifying circumstance.

Case Digest (G.R. No. 232070)
Expanded Legal Reasoning Model

Facts:

  • Parties and Charge
    • Appellants Romeo Welbar Padal, Jr., Reynan Padal, and two other John Does were charged by Amended Information dated June 3, 2009, with the murder of Ragnel Salcedo Laguardia in Davao City on or about December 31, 2007.
    • They were alleged to have conspired and attacked Ragnel with a knife and a gun, using a motor vehicle to facilitate the crime, inflicting fatal wounds that caused his death.
    • The case was raffled to Regional Trial Court (RTC), Branch 11, Davao City.
  • Events Leading to the Crime
    • On December 31, 2007, the victim Ragnel and friends (including Eric Bugayong, Allan Cordero, Ezzer Francisco, Ron Calapre, and Albert Tancontian) finished singing videoke at about 2 a.m. at the Land Transportation Terminal, Ecoland, Davao City.
    • While heading home, four men on a motorcycle approached them—later identified as the appellants plus two other John Does.
    • Ragnel, Albert, Ron, and Ezzer accompanied three of those men to a vacant lot, while Eric and Allan went ahead to wait at the Ateneo.
  • The Attack
    • About an hour later, the four men on the motorcycle ran after the group.
    • Romeo Padal grabbed Ragnel by the hair, causing him to fall, then kicked and stabbed him four times with a sharp pointed metal object.
    • Reynan Padal and the other two John Does blocked Eric and Allan from assisting Ragnel, with Reynan firing a sumpak (a firearm), causing the group to flee.
    • Ragnel was brought to the hospital but was declared dead on arrival.
  • Identification and Investigation
    • Ragnel’s father, Edgar Laguardia, helped conduct surveillance with witnesses and CIDG officers to identify the assailants.
    • Romeo and Reynan were positively identified at a habal-habal terminal and later detained at the police station.
  • Medical and Financial Details
    • The medico-legal report concluded death was due to massive pneumo-hemothorax from stab wounds that pierced the pulmonary vein, causing lung collapse and substantial blood loss.
    • The funeral expenses reached P65,000, with receipts evidencing costs amounting to P38,500.
  • Defense and Trial Court Decision
    • Appellants interposed alibi defenses, claiming they were at home or working as motorcycle passengers callers during the relevant time.
    • The RTC convicted appellants of murder on June 13, 2013, sentencing them to reclusion perpetua and ordering indemnity, actual damages, and civil damages, holding that the use of a motor vehicle qualified the killing to murder.
  • Appeal to the Court of Appeals
    • Appellants argued lack of positive identification, asserting the view was obscured during the stabbing.
    • The OSG maintained the credibility of eyewitnesses and the sufficiency of the prosecution's evidence.
    • The CA affirmed the RTC conviction on March 10, 2017, giving full faith to the eyewitnesses and rejecting the alibi defense.
  • Present Appeal to the Supreme Court
    • Appellants renewed their plea for acquittal.
    • Both parties adopted their briefs from the CA proceedings.

Issues:

  • Whether the Court of Appeals erred in affirming the conviction of appellants for murder.
  • Whether the positive identifications of the appellants by the prosecution witnesses were credible and sufficient to prove guilt beyond reasonable doubt.
  • Whether the defense of alibi was properly rejected.
  • Whether the killing qualified as murder due to the use of a motor vehicle.
  • Whether treachery attended the commission of the crime.
  • Proper award and modification of damages.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.