Case Digest (G.R. No. 111709) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Roger P. Tulin, Virgilio I. Loyola, Cecilio O. Changco, Andres C. Infante, Jr., and Cheong San Hiong (G.R. No. 111709, August 30, 2001), the cargo vessel M/T Tabangao, owned by PNOC Shipping and Transport Corporation and loaded with petroleum products valued at ₱40,426,793.87, was sailing off Mindoro on March 2, 1991, when seven armed men led by Emilio Changco seized it by ladder. Among the pirates were appellants Tulin, Loyola, Infante, and Cecilio Changco, armed with rifles, handguns, and bolos. They detained the 21‐member crew, repainted the vessel “Galilee,” and sailed to Singapore under false radio reports. On March 28 and 30, they transferred the cargo to the “Navi Pride”, supervised by accused‐appellant Cheong San Hiong, who falsified crew lists and declarations. The pirates returned to Batangas on April 10, 1991, released the crew under threat, and dispersed. Crew members filed sworn statements with PNOC, the Coast Guard, and the NBI. Betw Case Digest (G.R. No. 111709) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Vessel, Cargo, and Crew
- M/T Tabangao, owned by PNOC Shipping and Transport Corporation, loaded with 2,000 barrels of kerosene, 2,600 barrels of regular gasoline, and 40,000 barrels of diesel oil (total value ₱40,426,793.87), manned by 21 crew members.
- On March 2, 1991, off Silonay Island, Mindoro, seven armed pirates led by Emilio Changco boarded the vessel using an aluminum ladder, detained the crew, and took control.
- Piratical Acts and Cargo Transfer
- The pirates repainted the vessel “Galilee” (registry: Honduras), sent false repair messages to PNOC, and forced the crew to sail to Singapore.
- From March 28 to 30, 1991, the pirates transferred the vessel’s petroleum cargo to the “Navi Pride” under the supervision of accused-appellant Cheong San Hiong.
- Crew Release, Arrests, and Charge
- On April 10, 1991, the crew was released in three batches under threat; they reported the incident on April 12 to PNOC, the Coast Guard, and the NBI.
- Between May 19–20, 1991, NBI agents arrested appellants Tulin, Loyola, Infante, Cheong San Hiong, and Cecilio Changco.
- On October 24, 1991, an Information was filed for qualified piracy in Philippine waters (PD No. 532) against the six appellants and nine John Does.
Issues:
- Whether appellants validly waived the right to counsel despite initial representation by a non-lawyer.
- Whether confessions obtained without counsel during custodial investigation are admissible.
- Whether the prosecution proved beyond reasonable doubt that appellants committed qualified piracy.
- Whether Republic Act No. 7659 superseded PD 532 and obliterated piracy in Philippine waters as to Cheong San Hiong.
- Whether Hiong, charged as principal, may be convicted only as accomplice for acts partly committed outside Philippine waters.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)