Case Digest (G.R. No. 262579) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 262579, decided on February 28, 2024 under the 1987 Philippine Constitution, the People of the Philippines charged Rossano Samson y Tiongco with Murder under Article 248 of the Revised Penal Code for the October 8, 2014 killing of eleven-year-old Abegail Tobias y Dela Torre in Norzagaray, Bulacan. The Information alleged that appellant, armed with a crowbar and intent to kill, attacked the minor with treachery and abuse of superior strength, inflicting blows that caused instantaneous death. At the Regional Trial Court (Branch 18, Malolos City, Bulacan) in Criminal Case No. 4160-M-2014, the prosecution presented the victim’s father who traced blood drops and identified a pendant found at appellant’s doorstep; Senior Police Officer Diaz who investigated the scene, recovered the crowbar, and arrested appellant in Navotas; and Atty. Villegas of the Public Attorney’s Office who witnessed and assisted in appellant’s voluntary extrajudicial confession. Appellant denied guil Case Digest (G.R. No. 262579) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Case Background
- Accusation and Information
- Rossano Samson y Tiongco was charged with Murder under Article 248 of the Revised Penal Code for killing eleven-year-old Abegail Tobias y Dela Torre on October 8, 2014 in Norzagaray, Bulacan.
- The Information alleged use of a crowbar, intent to kill, abuse of superior strength, and treachery.
- Procedural History
- Accused pleaded “Not Guilty” and underwent trial before RTC Branch 18, Malolos City (Crim. Case No. 4160-M-2014).
- RTC found him guilty on July 20, 2020; imposed reclusion perpetua sans parole and awarded damages.
- Court of Appeals (CA) affirmed on April 19, 2022 (CA-G.R. CR HC No. 14958).
- Appeal to the Supreme Court ensued.
- Prosecution’s Evidence
- Eyewitness and Crime Scene Findings
- Victim’s father, Jeremias Dela Torre, met accused at ~6:30 p.m., later found blood in the house and discovered Abegail’s lifeless body across the road.
- Victim’s blouse disarrayed and underwear displaced; Medico-Legal Report documented 32 injuries, three fatal to the head.
- Police Investigation and Physical Evidence
- SPO3 Dennis Diaz tied accused to a drinking spree; only accused left the group.
- A plastic bead (earring pendant) was recovered at accused’s doorstep and identified by the victim’s father.
- Crowbar used in the killing was later recovered in accused’s room.
- Accused fled to his father’s house in Navotas and was found sleeping on the second floor.
- Confession and Legal Assistance
- While en route to the station, accused admitted killing Abegail with a crowbar.
- Extrajudicial confession executed in writing at the station with Atty. Mario M. Villegas (PAO) present; accused repeatedly said “Nakukunsensya na ako,” and was informed of rights against self-incrimination.
- Defense Version
- Denial and Alibi
- Accused claimed he only learned of the incident on October 9 or 10, 2014.
- He went to Navotas for rice and money; police came three days later.
- He denied signing any confession knowingly, asserting he could not read the document.
- RTC Decision
- July 20, 2020 Decision
- Convicted accused of Murder with treachery and abuse of superior strength.
- Sentence: reclusion perpetua without eligibility for parole; civil indemnity ₱100,000.00; actual damages ₱50,570.00; moral damages ₱100,000.00; exemplary damages ₱100,000.00; 6% interest.
- CA and Supreme Court Proceedings
- CA Ruling
- On April 19, 2022, CA denied appeal, affirmed RTC Decision in toto.
- Supreme Court Appeal
- SC dismissed appeal; affirmed conviction; clarified treachery absorbed abuse of superior strength; modified damages in conformity with People v. Jugueta.
Issues:
- Whether the CA erred in admitting the accused-appellant’s extrajudicial confession.
- Whether the CA erred in affirming the conviction based on circumstantial evidence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)