Case Digest (G.R. No. 173476) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Rodrigo Salafranca y Bello, G.R. No. 173476, decided on February 22, 2012, the accused-appellant, Rodrigo Salafranca, was charged before the Regional Trial Court (RTC), Branch 18, Manila, with murder for fatally stabbing Johnny Bolanon past midnight on July 31, 1993, near the Del Pan Sports Complex in Binondo, Manila. According to eyewitness testimony of 13-year-old Augusto Mendoza, Salafranca approached Bolanon from behind, encircled his left arm around the victim’s neck, and inflicted two blows with his right hand, one at the right subcostal area. Bolanon was able to walk to his uncle Rodolfo Estaño’s house, who rushed him by taxi to the Philippine General Hospital. During the trip, Bolanon, suffering from labored breathing, declared that Salafranca was his assailant; he died upon arrival at 2:30 a.m. Salafranca evaded arrest until April 23, 2003. The RTC, finding treachery and the dying declaration credible, convicted him of murder under Articl Case Digest (G.R. No. 173476) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- The stabbing incident
- On July 31, 1993, past midnight, Johnny Bolanon was fatally stabbed near the Del Pan Sports Complex in Binondo, Manila.
- The assailant fled immediately after delivering two blows, one to the right subcostal area and another below the left nipple.
- Rescue and dying declaration
- Despite his wounds, Bolanon walked to his uncle Rodolfo B. Estaño’s house to seek help.
- On the way by taxicab to the Philippine General Hospital, Bolanon told Estaño that Rodrigo Salafranca y Bello was his attacker.
- Bolanon died at 2:30 a.m. in the emergency room.
- Witness identification and arrest
- Thirteen-year-old Augusto Mendoza witnessed the attack, positively identifying Salafranca as the culprit.
- Salafranca evaded arrest until April 23, 2003, when he was detained at the Manila City Jail.
- Trial court and appellate proceedings
- The Regional Trial Court (RTC) convicted Salafranca of murder with the qualifying aggravating circumstance of treachery and sentenced him to reclusion perpetua.
- The Court of Appeals (CA) affirmed the conviction and the award of ₱50,000 death indemnity.
- Salafranca appealed to the Supreme Court, challenging witness credibility and the sufficiency of evidence.
Issues:
- Whether Bolanon’s ante-mortem statements are admissible as a dying declaration or part of the res gestae.
- Whether the identification by Mendoza and Bolanon’s declaration to Estaño suffice to prove Salafranca’s guilt beyond reasonable doubt.
- Whether the award of civil damages should be limited to the ₱50,000 death indemnity or expanded to include moral, temperate, and exemplary damages.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)