Case Digest (G.R. No. 175023) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On the evening of March 8, 1999, at the University of the Philippines Diliman campus, a melee erupted between two rival groups in which Giovani Serrano y Cervantes (petitioner) and fifteen to eighteen participants were involved. During that fracas, Anthony Galang was stabbed in the abdomen and later identified the petitioner as his assailant. An Information for frustrated homicide was filed against Serrano on March 11, 1999, before the Regional Trial Court (RTC), Branch 83, Quezon City, to which he pleaded not guilty on March 20, 2000. Through stipulations, the parties dispensed with certain witnesses, and the trial on the merits focused on the victim’s positive in-court and out-of-court identification, the lighting conditions, and whether the wound was mortal. On October 25, 2004, the RTC convicted Serrano of frustrated homicide and sentenced him to four years, two months, and one day to ten years of prision mayor, plus an award of P19,000.00 in damages. The Court of Appeals (C Case Digest (G.R. No. 175023) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Incident
- On March 8, 1999, a street brawl erupted at University of the Philippines–Diliman between two rival groups, including petitioner Giovani Serrano y Cervantes and victim Anthony Galang y Lagunsad.
- During the melee, Galang was stabbed in the left abdomen; he was rushed to UP Infirmary and referred to East Avenue Medical Center, where surgery was performed.
- Procedural History
- Petitioner was charged on March 11, 1999 with frustrated homicide, pleaded not guilty on March 20, 2000, and stipulated certain investigative facts to dispense with live testimony of SPO2 dela Paz and the hospital records custodian.
- At trial, the prosecution presented witnesses Anthony Galang (victim), Arlo Angelo Arceo, Sgt. Rolando Zoleto, and SPO2 Roderick Dalit; the defense presented the petitioner, his brother Gener Serrano, and George Hipolito.
- Lower Court Decisions
- The Regional Trial Court (RTC), Branch 83, Quezon City, convicted petitioner of frustrated homicide and sentenced him to 4 years, 2 months, 1 day to 10 years imprisonment, ordering indemnity of ₱19,000.00.
- On appeal (CA-G.R. CR No. 29090), the Court of Appeals modified the conviction to attempted homicide, imposed 6 months arresto mayor to 4 years, 2 months prision correccional, reduced actual damages to ₱3,858.50, and deleted loss earnings.
- Petitioner filed a Rule 45 petition for review on certiorari before the Supreme Court.
Issues:
- Identification and Credibility
- Whether the Court of Appeals erred in giving full credence to the victim’s allegedly inconsistent testimony.
- Whether the CA improperly relied on speculative and conjectural prosecution testimony.
- Proof of Intent and Injury
- Whether the chaotic brawl setting precludes positive identification of the assailant.
- Whether the evidence establishes intent to kill and a fatal wound sufficient for frustrated homicide.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)