Case Digest (G.R. No. 150224) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Joel Yatar alias aKawita, G.R. No. 150224, decided on May 19, 2004, the Regional Trial Court of Bulanao, Tabuk, Kalinga, Branch 25 convicted appellant Joel Yatar for the special complex crime of Rape with Homicide, sentencing him to death and ordering payment of civil indemnity, moral, exemplary and actual damages. On June 30, 1998, in Liwan West, Rizal, Kalinga, seventeen-year-old Kathylyn Uba was alone at her grandmother Isabel Dawang’s house after relatives left for the farm. Earlier that morning, Kathylyn had delivered to appellant a letter from his estranged wife. Witnesses Anita Wania and Beverly Deneng saw Yatar behind the house at 10:00 a.m.; Judilyn Pas-a observed him descending the ladder at 12:30 p.m. and again at 1:30 p.m., behaving oddly and changing shirts. That evening, Isabel found Kathylyn’s naked body on the second floor with multiple stab wounds and her intestines protruding. Police discovered semen in Kathylyn’s vaginal canal Case Digest (G.R. No. 150224) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- Appellant Joel Yatar alias “aKawita” was charged by Information with the special complex crime of rape with homicide under Article 266-A, as amended by R.A. 8353, for the death of his 17-year-old cousin Kathylyn D. Uba on June 30, 1998, at Liwan West, Rizal, Kalinga.
- The Regional Trial Court of Bulanao, Tabuk, Kalinga, Branch 25, convicted him of rape with homicide, sentenced him to death, and ordered payment of civil indemnity (P75,000), moral damages (P200,000), exemplary damages (P50,000), actual damages (P186,410), and costs.
- Chronology of Events
- Morning of June 30, 1998 – Kathylyn alone at grandmother Isabel Dawang’s house; earlier delivered a letter from Luz Yatar to appellant. Witnesses (Anita Wania, Beverly Deneng) saw appellant in the back of the house.
- Afternoon – Judilyn Pas-a observed appellant descending ladder at 12:30 p.m. and again at 1:30 p.m., wearing different shirts, appearing agitated; appellant fled when approached.
- Evening – Isabel found Kathylyn’s naked, bloodied body upstairs, intestines protruding; neighbors and police arrived; evidence collected (victim’s garments, blood-stained shirt).
- Forensic and Custodial Facts
- Autopsy by Dr. Bartolo revealed eleven wounds (six stab, five incised), full rigor mortis by 9:00 a.m. July 1 (death estimated 9 a.m.–12 p.m. June 30), presence of semen but no hymenal laceration.
- DNA testing via PCR-STR at U.P. NSRI matched semen in victim’s vaginal slides and blood-stained shirt to appellant’s blood sample (identical gene markers).
- Appellant initially denied knowledge, was placed in custody, attempted escape on July 3, 1998, but was recaptured within 70 meters.
Issues:
- Whether the trial court erred in giving weight to prosecution evidence despite alleged doubts in witness credibility.
- Whether the evidence failed to overcome reasonable doubt, warranting appellant’s acquittal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)