Case Digest (G.R. No. 145222) Core Legal Reasoning Model
Facts:
The case at hand is People of the Philippines vs. Alberto Petalino (G.R. No. 213222) decided by the Supreme Court of the Philippines on September 24, 2018. The events leading to the case began on November 30, 1997, in Iloilo City, Philippines, where the accused-appellant, Alberto Petalino, alias "Lanit," was charged with murder. The charge stemmed from an incident where Petalino allegedly stabbed the victim, Johnny Nalangay, at a late-night gathering. The prosecution's primary eyewitness, Franklin Bariquit, testified that he was with Nalangay when they decided to walk towards the YMCA to catch transportation home. As they walked through a narrow alley, Petalino approached from the opposite direction, unexpectedly attacked Nalangay by grabbing his hair and stabbing him in the back. Despite Nalangay's attempt to flee, he fell to the ground, severely injured, and subsequently died at St. Paul’s Hospital shortly after the incident. The victim's father, Jaime N
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Case Digest (G.R. No. 145222) Expanded Legal Reasoning Model
Facts:
- Procedural and Charging Background
- The accused-appellant, Alberto Petalino alias "Lanit", was charged with murder through an information dated February 19, 1998 for killing Johnny Nalangay on November 30, 1997 in Iloilo City.
- The information alleged that the accused, armed with a knife and employing treachery and evident premeditation, willfully attacked the victim resulting in fatal injuries to vital parts of his body.
- Prosecution’s Version of Events
- Eyewitness Testimony by Franklin Bariquit
- Bariquit, who attended a party in Barangay Danao, Iloilo City, recounted that he met the victim and later accompanied him as they were leaving to secure rides home.
- While walking down a narrow alley, the victim and Bariquit encountered the accused coming from the opposite direction.
- According to Bariquit, the accused suddenly turned toward the victim, grabbed his hair, and without warning, stabbed him in the back.
- Following this, a confrontation ensued between Bariquit and the accused, which led to the accused dropping his knife.
- Bariquit then sought help while the victim, after attempting to evade, was found lying bloodied on the ground and later pronounced dead at the hospital.
- Testimony of the Victim’s Father, Jaime Nalangay
- Confirmed that the victim was 20 years old at the time of his death.
- Stated that he was informed about his son’s stabbing by a police officer and was present at the hospital, only to find his son had already died.
- Claimed that he incurred expenses for embalming and burial, and expressed the immeasurable pain caused by the death.
- Defense’s Version of Events
- Accused-Appellant’s Testimony
- The accused testified that on the night of November 30, 1997, he was at his sister’s store in Iloilo City and left after assisting customers.
- He claimed that upon entering a narrow alley, he encountered two persons, one of whom, a certain Bariquit, called him “Lanit”.
- He explained that an accidental bump occurred when he turned his back, leading to an unintended collision with the victim, for which he apologized.
- Allegedly, the victim then became aggressive—boxing him in the chest—causing the accused to lose control and punch the victim in self-defense.
- The accused claimed that as the victim recovered and drew a knife, a struggle ensued, prompting him to flee when the victim’s companions, who were intoxicated, tried to intervene.
- Court Decisions Prior to the Supreme Court
- Regional Trial Court (RTC) Judgment (January 24, 2013)
- Found the accused guilty beyond reasonable doubt of murder based on the prosecution’s evidence and the credible eyewitness identification.
- Imposed the penalty of reclusion perpetua along with accessory penalties and civil liabilities, including indemnity, moral, exemplary, and temperate damages to be paid to the victim’s heirs.
- Court of Appeals (CA) Decision (April 24, 2014)
- Affirmed the RTC’s ruling, emphasizing that the inconsistencies in the eyewitness testimony were minor and did not undermine Bariquit’s credibility.
- Upheld the finding that treachery was present in the execution of the crime, thereby justifying the murder conviction.
- Allegations Raised by the Accused-Appellant on Appeal
- Argued that his denial and alibi should have prevailed over the positive identification by the eyewitness.
- Claimed that the qualifying circumstance of treachery did not stand as the prosecution failed to establish the necessary elements for its appreciation.
Issues:
- Whether the prosecution established the accused-appellant’s guilt beyond reasonable doubt despite his denial and alibi, given the positive identification by the eyewitness.
- Whether the prosecution sufficiently proved the qualifying circumstance of treachery, particularly that the accused consciously adopted a mode of execution which left the victim without any opportunity to defend himself or retaliate.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)