Case Digest (G.R. No. L-35156) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Esmeraldo Rivera, Ismael Rivera, and Edgardo Rivera v. People of the Philippines (G.R. No. 166326, January 25, 2006), the petitioners were charged with attempted murder in the Regional Trial Court (RTC) of Imus, Cavite. The Information alleged that on May 3, 1998 in Dasmariñas, Cavite, the three brothers, conspiring and armed with apparent treachery and premeditation, mauled and struck one Ruben Rodil with fists and a hollow block, inflicting non‐mortal head injuries and other contusions. Rodil, a former taxi driver, had a heated exchange a day earlier with Edgardo Rivera at a neighborhood store. On the following evening, the Riveras ambushed Rodil—Esmeraldo and Ismael pummeling him while Edgardo delivered three blows with a hollow block. Bystanders intervened and police arrived, prompting the assailants to flee. Medical records showed slight lacerations and contusions that would heal within days, though back pain persisted for a month. The RTC, on August 30, 2002, found the Case Digest (G.R. No. L-35156) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and antecedents
- Petitioners Esmeraldo, Ismael and Edgardo Rivera, residents of Dasmariñas, Cavite; private complainant Ruben Rodil, former taxi driver, lived nearby.
- Prior altercation in April 1998: Rodil stopped driving due to a separate threat; incident between Rodil and Edgardo over remarks about Rodil’s livelihood.
- Incident of May 3, 1998
- Sequence of events:
- At about 7:30 p.m., Rodil, with his three-year-old daughter, went to a store; petitioners emerged, mauled him with fists; Edgardo struck him thrice on the head with a hollow block; Ismael joined by throwing a stone.
- Bystanders intervened; police arrived; petitioners fled; Rodil was taken to hospital.
- Injuries and medical report:
- Lacerated wound on parietal area (slight, 1–7 days healing), cerebral contusion, hematoma on buttocks, multiple abrasions, periorbital hematoma.
- One-month medication prescribed for back pain.
- Procedural history
- RTC of Imus, Cavite (Branch 90) – August 30, 2002: found petitioners guilty of frustrated murder; sentenced to 6 years +1 day to 8 years prision mayor; ordered joint civil indemnity of ₱30,000.
- Court of Appeals – June 8, 2004: affirmed with modification; convicted petitioners of attempted murder; imposed indeterminate penalty of 2 years prision correccional (minimum) to 6 years +1 day prision mayor (maximum).
- Supreme Court petition: petitioners contended absence of intent to kill and treachery; prosecution argued evidence of intent and sudden attack; OSG supported CA decision.
Issues:
- Whether the prosecution proved beyond reasonable doubt petitioners’ specific intent to kill and the qualifying circumstance of treachery to sustain an attempted murder conviction.
- Whether the penalty imposed by the Court of Appeals correctly reflects the law and applicable reductions for attempted murder.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)