Case Digest (G.R. No. 211564) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Enrique aTotoya Rivera y de Guzman vs. People of the Philippines, petitioner Enrique aTotoya Rivera was charged with direct assault under Article 148 of the Revised Penal Code before the Regional Trial Court (RTC) of La Trinidad, Benguet. On May 6, 1993, the Information alleged that on March 20, 1993 at Tomay, Shilan, La Trinidad, Benguet, petitioner unlawfully attacked Police Lieutenant Edward M. Leygo—Deputy Chief for Operations and Patrol—while the latter was performing official duties enforcing La Trinidad Municipal Ordinance No. I-91 (prohibiting unloading of chicken dung along the highway). According to the prosecution, Leygo ordered a truck driver to cease unloading, escorted the vehicle back, and later, upon finding the same truck returning, confronted petitioner who had ordered the driver to defy the ban. Petitioner allegedly hurled insults, assumed a fighting stance, removed his jacket, and punched Leygo on the lip, inflicting a contusion and laceration. Police witn Case Digest (G.R. No. 211564) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural History
- An information for direct assault was filed on May 6, 1993 in the Regional Trial Court (RTC) of La Trinidad, Benguet against petitioner Enrique aTotoya Rivera.
- On April 22, 1994, the RTC convicted Rivera of direct assault, sentencing him to an indeterminate penalty of four months and one day of arresto mayor as minimum to one year, one month and eleven days of prisión correccional as maximum, plus a fine of ₱500.00 and costs.
- Rivera’s motion for reconsideration was denied, and he appealed to the Court of Appeals (CA) under CA-G.R. CR No. 17284.
- On October 16, 1998, the CA affirmed the RTC decision in toto and, on April 5, 1999, denied his motion for reconsideration.
- Petitioner then elevated the case to the Supreme Court via a petition for review on certiorari.
- Incident and Trial
- On March 20, 1993, at around 8:00 PM in Shilan, La Trinidad, Lt. Edward M. Leygo (Deputy Chief of Police for Operations) and SPO1 Joseph Basquial were on patrol when they stopped a truck unloading chicken dung in violation of Municipal Ordinance No. I-91.
- The driver complied and returned the truck to Poblacion, La Trinidad; later, SPO1 Bangcado and SPO1 Rivera Dayap stopped the same truck elsewhere and radioed Leygo, who ordered them to restrain it.
- Petitioner appeared, instructed the driver to defy the police, and followed the truck in his own vehicle back to Dengsi, Tomay, where Leygo’s group overtook them.
- A confrontation ensued: petitioner hurled insults, removed his jacket, assumed a fighting stance, and punched Lt. Leygo in the face, inflicting a contusion and a 0.5 cm laceration on the upper lip.
- Leygo and his men subdued and arrested petitioner; both were taken to Benguet General Hospital for medico-legal examination (Leygo: contusion with 0.5 cm laceration of the left upper lip, healing 5–7 days; petitioner: erythema of the left lip and a contusion in the midepigastric area, healing 3–5 days).
- At trial, the prosecution presented Leygo, SPO1 Bangcado, and eyewitness Brenda Dup-et; the defense offered petitioner and Alfredo Castro.
Issues:
- Whether Lt. Leygo’s testimony was credible and sufficient to prove direct assault beyond reasonable doubt.
- Whether the assault occurred while Lt. Leygo was performing his official duties.
- Whether corroboration by co-policemen or the attending physician was necessary for conviction.
- Whether the trial court properly assessed the credibility of witnesses and petitioner’s demeanor.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)