Case Digest (G.R. No. 208393) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Eduardo Ukay y Monton a.k.a. “Tata,” Teodulo Ukay y Monton a.k.a. “Jun-jun,” Guillermo Dianon a.k.a. “Momong,” and Oca Ukay y Monton (G.R. No. 246419, decided September 16, 2020 under the 1987 Constitution), the Regional Trial Court (Branch 11, Davao City) docketed two Informations: Crim. Case No. 61,566-07 for Frustrated Murder (Art. 248 RPC, in relation to Art. 6 RPC) and Crim. Case No. 61,568-07 for Murder (Art. 248 RPC). On June 12, 2007 at around 10:00 p.m., Jessie C. Gerolaga and his cousin Anthony Aloba left a drinking spree at their aunt’s house in Emily Homes, Cabantian, Davao City. At a nearby convenience store they encountered accused-appellants Eduardo, Teodulo, Guillermo, and Oca. A quarrel erupted between Guillermo and his wife; Anthony intervened, and a scuffle ensued. As Jessie and his brother Warren turned to leave, Oca stabbed Warren in the shoulder; Jessie was then slashed in the abdomen and armpit by Oca and Eduardo. Anthony w Case Digest (G.R. No. 208393) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Charges
- Crim. Case No. 61,566-07 – Frustrated Murder
- Accused: Eduardo Ukay y Monton @ “Tata” and Oca Ukay y Monton
- Victim: Jessie C. Gerolaga
- Information: Armed with knives, with intent to kill, with treachery, conspired to stab Jessie, performed all acts to commit murder but victim survived due to medical assistance
- Crim. Case No. 61,568-07 – Murder
- Accused: Eduardo Ukay y Monton @ “Tata,” Teodulo Ukay y Monton @ “Jun-jun,” Guillermo Dianon @ “Momong,” and Oca Ukay y Monton
- Victim: Anthony Aloba
- Information: Conspiring together, armed with knives, with intent to kill, with treachery and taking advantage of superior strength, attacked and fatally stabbed Anthony
- Incident Narratives
- Prosecution’s Version
- June 9, 2007, around 10:00 p.m., Davao City convenience store: drinking spree ended in verbal spat between Guillermo and his wife, Anthony intervened
- Fight ensued; Warren Gerolaga pacified his brother Jessie, who then turned away; Oca stabbed Warren, Eduardo stabbed Jessie (intestines protruded)
- Group assaulted Anthony with knives, stone, kicks; Anthony later died at hospital
- Defense’s Version
- Accused were drinking when Anthony, Jessie and another approached and provoked fight by grabbing Guillermo and throwing stones
- Guillermo was beaten, Eduardo fled; Teodulo called police; Eduardo and Teodulo later surrendered to authorities
- Lower Court Rulings
- Regional Trial Court (March 11, 2013)
- Found Eduardo guilty of Frustrated Murder (Jessie) – sentenced to 10 years+1 day to 12 years+1 day of prision mayor and reclusion temporal
- Found Eduardo, Teodulo, Guillermo guilty of Murder (Anthony) – reclusion perpetua and damages of ₱50,000 actual, ₱50,000 civil indemnity
- Court of Appeals (November 23, 2018)
- Affirmed RTC’s guilt findings on treachery and conspiracy; modified damages per jurisprudence
- Awarded actual and exemplary damages totalling ₱75,000 each for Anthony’s heirs; ₱50,000 each for Jessie
Issues:
- Information Defect and Waiver
- Whether the Informations’ mere statement “with treachery” sufficiently alleged factual basis for treachery
- Whether accused-appellants waived defects by not filing motion to quash or bill of particulars
- Proof of Treachery
- Whether treachery was established by “unexpected” and “deliberate” attack alone
- Whether provocation and impulsive reaction negate treachery
- Proper Crime Classification
- Whether conviction should remain Murder and Frustrated Murder qualified by treachery
- Whether crimes should be downgraded to Homicide and Frustrated Homicide
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)