Case Digest (G.R. No. 126029) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On June 29, 1994 in Puerto Princesa City, Palawan, the mutilated body of AAA, a 15-year-old high school student of Palawan Integrated National School, was discovered in a secluded coffee plantation in Barangay Bancao-Bancao. Following swift police action and a preliminary investigation by the Municipal Trial Court in Cities, an information for rape with homicide was filed on September 6, 1994 in the Regional Trial Court (Branch 48), Criminal Case No. 11984, against Rey Sunga, Ramil Lansang, Inocencio Pascua, Jr., Lito Octac as principals, and Locil Cui alias Ginalyn Cuyos as accomplice. All pleaded not guilty and petitioned for bail. During the bail hearings, the prosecution moved to discharge Locil under Rule 119, Section 9 as a state witness, submitting her detailed sworn statement about how the accused forcibly fetched AAA, raped her in Barangay Irawan, then stabbed and bludgeoned her to death. The defense opposed, but the trial court granted the discharge and resumed trial. Case Digest (G.R. No. 126029) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Incident and Investigation
- On June 29, 1994 at around 2:00 p.m., the mutilated body of AAA, a 15-year-old high school student, was found at a coffee plantation in Jacana, Barangay Bancao-Bancao, Puerto Princesa City, Palawan.
- A manhunt ensued; five individuals—Rey Sunga, Ramil Lansang, Inocencio Pascua, Lito Octac and Locil Cui (alias Ginalyn Cuyos)—were arrested and charged with rape with homicide before the Regional Trial Court (RTC), Branch 48.
- Preliminary Proceedings
- The accused pleaded not guilty and petitioned for bail, arguing the People had no direct evidence.
- On October 18, 1994, the prosecution moved to discharge Locil as an accomplice and turn her into a state witness, submitting her sworn statement detailing how the crime was committed.
- The RTC granted Locil’s discharge and refused bail pending resolution on the merits; an attempted TRO in the Court of Appeals lapsed, and trial proceeded.
- Prosecution Evidence
- State Witness Testimony
- Locil (14 years old) testified she was lured by one “lesbian” into a tricycle with AAA; they were driven to a forested area in Barangay Irawan.
- She recounted AAA being pinned, raped sequentially by Lansang, Sunga and “Pascua,” then stabbed and bludgeoned to death.
- Locil helped dispose of the body and was later threatened to remain silent until her arrest on July 12, 1994.
- Other Witnesses and Autopsy
- Oscar Devilleres saw Lansang near the crime scene at night; Igleceria Gabinete saw three suspicious men near AAA’s corpse.
- Galahad Tan (victim’s father) testified Lansang suggested they not inform police and that he knew someone who could identify the killers.
- Dr. Ma. Carla Gallego-Vigonte performed the autopsy, finding depressed skull fractures and intracranial hemorrhage as cause of death but could not confirm rape.
- Documentary Evidence
- Two extrajudicial statements by Sunga (Exhibits “A” and “I”) narrated similar events but conflicted in dates, participants and details.
- Defense Case
- All accused asserted alibis and denied participation; Sunga challenged Locil’s credibility and claimed his statements were coerced and inadmissible.
- Pascua and Octac presented alibi witnesses and employment records proving they were elsewhere on June 29, 1994.
- Lansang produced bank tellers, receipts, and family witnesses to show he was in Puerto Princesa City proper, attending to errands from morning until evening on June 29, 1994.
- Trial Court Decision
- On March 7, 1996, the RTC convicted Sunga and Lansang of rape with homicide (death penalty) and Pascua of rape (reclusion perpetua), acquitting Octac and ordering the release of Locil unless held for other causes.
- Automatic review ensued before the Supreme Court.
Issues:
- Discharge of Locil Cui as State Witness
- Whether the RTC’s grant of discharge under Rule 119, Sec. 9 was proper and complied with legal requisites.
- Sufficiency and Admissibility of Evidence
- Whether the prosecution proved appellants’ guilt beyond reasonable doubt, considering the uncorroborated testimony of a co-accused turned state witness.
- Whether Sunga’s extrajudicial statements were admissible against him and co-accused.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)