Case Digest (G.R. No. 104663) Core Legal Reasoning Model
Facts:
In the case People of the Philippines vs. David Salvatierra y Eguia, decided on July 24, 1997, the accused-appellant David Salvatierra was charged with the murder of Charlie Fernandez y De Guzman. The crime occurred on August 17, 1990, in Manila, when Charlie Fernandez, a street vendor, was fatally stabbed by appellant and two others. At approximately 4:30 PM, as Charlie was walking along M. de la Fuente Street towards Quiapo, he was suddenly confronted by three men, one of whom was identified by an eyewitness, Milagros Martinez, as David Salvatierra. Appellant stabbed Charlie in the left breast, after which all three assailants fled. Charlie managed to return home but later collapsed and was rushed to the hospital. Despite surgical intervention, he died the following day from hemorrhage caused by the stab wounds.
The police were initially unable to identify the assailants, but a relative of the victim later identified appellant as a suspect. Appellant was arrested on November
Case Digest (G.R. No. 104663) Expanded Legal Reasoning Model
Facts:
- Incident and Victim Background
- On August 17, 1990, at about 4:30 PM, Charlie Fernandez, a vendor of apalamiga, was walking along M. de la Fuente Street in Manila, heading towards Quiapo, on the opposite side of the street.
- Three persons suddenly met him, including accused David Salvatierra. Salvatierra lunged a pointed instrument at Charlie, who parried the first thrust. Salvatierra then swung the instrument again, inflicting a stab wound on Charlie’s left breast. The assailants fled immediately afterward.
- Despite the wound, Charlie managed to walk home to inform his father before collapsing and was rushed to the hospital for surgery.
- Witness and Initial Reporting
- Milagros Martinez, a fish and salted egg vendor, witnessed the assault from a nearby street corner near the Trabajo Market but only confided the incident to her daughter due to fear of retaliation.
- Charlie’s father, Marciano Fernandez, reported the incident to the police at Station No. 4 around 5:40 PM. The victim could not be interviewed post-assault as he was in surgery.
- Police and Marciano Fernandez conducted inquiries at the crime scene but no witnesses could immediately identify suspects. A relative later informed the police that Salvatierra was a suspect.
- Victim's Death and Police Investigation
- Charlie Fernandez passed away on August 18, 1990, due to hemorrhage resulting from the stab wound on the chest.
- The medico-legal report noted an additional stab wound on the left forearm and an incised wound on the left wrist.
- An advance information was prepared by the Western Police District indicating that four unidentified persons committed the offense.
- Arrest and Identification of Accused
- On November 15, 1990, Salvatierra was arrested at Miguelin Street for causing a commotion. Police later discovered he was a suspect in Charlie’s stabbing and transferred him to the Homicide Section of the Western Police District.
- Milagros Martinez, persuaded by Marciano Fernandez, executed a sworn statement identifying Salvatierra as the assailant.
- In a police line-up conducted on November 17, 1990, Milagros positively identified Salvatierra as the stabber.
- Charges and Defense
- Salvatierra was formally charged with murder on November 19, 1990, with allegations of conspiracy, intent to kill, treachery, and evident premeditation.
- At arraignment, Salvatierra pleaded not guilty and raised an alibi, claiming he was having merienda with his family at their home during the incident.
- He also alleged illegal arrest without a warrant, claimed deprivation of his right to counsel during investigation and police line-up, and contended the testimony of Milagros was vague, ambiguous, and unreliable.
- He further claimed forced signing of documents under duress.
Issues:
- Whether the arrest, investigation, and detention of accused violated his constitutional rights due to lack of a warrant and denial of the right to counsel.
- Whether treachery attended the killing, qualifying the offense as murder.
- Whether the identification of accused by eyewitness Milagros Martinez was credible and sufficient to convict.
- Whether the trial court erred in disregarding the accused’s alibi defense.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)