Case Digest (G.R. No. 131492) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case involves the People of the Philippines as the plaintiff-appellee against Catalino Quiming y Lopez, Herminigildo Lamigo, and Robin Estoesta, the accused, with Estoesta as the appellant. The incident under scrutiny occurred on May 28, 1983, when two dead bodies were discovered on the road in Barangay Carmay, Rosales, Pangasinan. The victims, Herminio Casimiro and Pedro Robina, had sustained multiple gunshot wounds, as confirmed by an autopsy that attributed their deaths to "shock, irreversible, due to massive internal and external hemorrhage, due to gunshot wounds." Nearby, investigators found sixteen empty bullet shells. The investigation led to the involvement of three soldiers from the 152nd PC Company, namely Estoesta, Lamigo, and Quiming, whose vehicle was identified at the crime scene with notable damage and bloodstains.During separate interrogations, each soldier implicated the others in the shooting. Subsequently, Estoesta was identified through a paraffin test
Case Digest (G.R. No. 131492) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
# Incident and Discovery of the Crime
On May 28, 1983, two dead bodies were found on the shoulder of a road in Barangay Carmay, Rosales, Pangasinan. The victims, Herminio Casimiro and Pedro Robina, had been sprayed with bullets. An autopsy revealed that the cause of death was "shock, irreversible, due to massive internal and external hemorrhage, due to gunshot wounds." Sixteen empty shells were recovered near the corpses.
# Investigation and Suspects
Investigation focused on three soldiers from the 152nd PC Company stationed in Lingayen, Pangasinan: Robin Estoesta, Herminigildo Lamigo, and Catalino Quiming. They had earlier used a mini-cruiser jeep, which was later found with a dented bumper and bloodstains at the rear. Upon separate interrogations:
- Estoesta pointed to Lamigo as the killer.
- Lamigo pointed to Estoesta.
- Quiming also pointed to Estoesta.
# Forensic Evidence
- Paraffin tests were positive for Estoesta and negative for Lamigo and Quiming.
- Ballistics tests showed that the empty shells came from firearms assigned to Quiming and Lamigo.
# Charges and Trial
On September 23, 1980, all three suspects were charged with double murder, committed with treachery and evident premeditation, and with the aggravating circumstance of taking advantage of their public position as members of the Philippine Constabulary. Each pleaded not guilty. Quiming was discharged as a state witness over the defense's objection.
# Trial Court Decision
After trial, Judge Manuel D. Victorio of the Regional Trial Court of Rosales, Pangasinan, found Estoesta guilty of double murder and sentenced him to reclusion perpetua for each offense, with indemnity of P30,000.00 to each victim's heirs. Lamigo was acquitted due to insufficient evidence.
Issues:
- Validity of Quiming's Discharge as a State Witness: The defense challenged Quiming's discharge, claiming his testimony was "perjurious" and contradictory.
- Credibility of Testimonies: The defense questioned the credibility of Quiming and Lamigo, alleging bias and inconsistencies in their testimonies.
- Presence of Aggravating Circumstances: Whether the killings were committed with treachery, evident premeditation, and with the aggravating circumstance of taking advantage of public position.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court affirmed the conviction of Robin Estoesta for double murder, modified the civil indemnity, and dismissed the appeal. The decision underscores the importance of adhering to legal requisites for discharging state witnesses, the deference given to trial courts in assessing witness credibility, and the need for stricter enforcement of discipline among law enforcement personnel.
- Estoesta pointed to Lamigo as the killer.
- Lamigo pointed to Estoesta.
- Quiming also pointed to Estoesta.