Case Digest (G.R. No. 213792) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Guillermo Wacoy y Bitol and James Quibac y Rafael v. People of the Philippines (G.R. No. 213792 & 213886, June 22, 2015), both petitioners were charged by Information dated June 10, 2004 with Homicide under Article 249 of the Revised Penal Code, alleging that on April 11, 2004 at Ambongdolan, Tublay, Benguet, they conspired to attack one Elner Aro y Laruan, delivering kicks and punches to his abdomen, inflicting blunt traumatic injuries that caused his death. Prosecution witness Edward Benito recounted seeing Wacoy kick Aro twice, pick up a rock (later restrained), and observe Quibac punch Aro as he staggered. Medical records showed perforation of the ileum, generalized peritonitis, and ultimately rupture of the aorta as the fatal injury. At the Regional Trial Court (RTC) of Benguet, Branch 10, petitioners denied intent to kill, claiming Aro was the aggressor and that their actions were defensive during a fistfight. The RTC, however, found them guilty only of Death Caused in Case Digest (G.R. No. 213792) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Information and Charge
- On June 10, 2004, Guillermo Wacoy y Bitol and James Quibac y Rafael were charged before RTC-Benguet, Branch 10, with Homicide under Article 249, RPC, for the April 11, 2004 killing of Elner Aro y Laruan at Ambongdolan, Tublay, Benguet—alleging conspiracy, intent to kill, assault with blunt force, and aggravation of superior strength.
- Trial court originally classified the offense as Death Caused in a Tumultuous Affray (Art. 251, RPC).
- Prosecution Evidence
- Eyewitness Edward Benito testified that at around 3 p.m., he saw Aro on the ground after Wacoy kicked his stomach twice, attempted to throw a rock, and Quibac punched Aro’s abdomen, causing collapse. Aro was later brought to the hospital.
- Medical records showed blunt abdominal trauma, perforation of the ileum, generalized peritonitis, and eventually cardiac arrest; autopsy cited “rupture of the aorta secondary to blunt traumatic injuries” as cause of death.
- Defense Version and Lower Courts’ Rulings
- Petitioners claimed Aro was drunk and unruly while they played pool; Wacoy picked up a stone but was restrained; a scuffle ensued involving Aro’s companion, Kinikin, not a concerted attack by petitioners.
- RTC (Feb. 28, 2011) found petitioners guilty of Death Caused in a Tumultuous Affray (Art. 251, RPC), sentencing them to 6 months+1 day to 8 years+1 day imprisonment and awarding P25,000 temperate damages, P50,000 civil indemnity, and P50,000 moral damages.
- CA (Dec. 6, 2013) modified the conviction to Homicide (Art. 249, RPC) with mitigating lack of intent to commit so grave a wrong, imposing an indeterminate term of 6 years+1 day prision mayor to 12 years+1 day reclusion temporal, and upheld interest on damages. July 21, 2014 resolution denied petitioners’ motions for reconsideration.
Issues:
- Whether the Court of Appeals correctly convicted petitioners of Homicide under Article 249, RPC, instead of Death Caused in a Tumultuous Affray under Article 251, RPC.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)