Case Digest (G.R. No. 150711) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Salvador Yapyuco y Enriquez et al. v. Honorable Sandiganbayan and the People of the Philippines (G.R. Nos. 120744-46, 122677, 122776, June 25, 2012), a joint trial arose from an April 5, 1988 shooting in Barangay Quebiawan, San Fernando, Pampanga. Lawmen—police officers Salvador Yapyuco, Jr., Generoso Cunanan, Jr., Ernesto Puno; barangay captains Jose Pamintuan, Mario Reyes, Andres Reyes; and civilian volunteers Virgilio Manguerra, Carlos David, Ruben Lugtu, Moises Lacson, Renato Yu, Jaime Pabalan—were accused of murder, frustrated murder, and multiple attempted murder for the death of Leodevince Licup and the wounding of Noel Villanueva aboard a green Toyota Tamaraw jeepney. After voluntary surrender in April 1991 (except for Pabalan, who had died), they pleaded not guilty. Prosecution witnesses Eduardo Flores, Noel Villanueva, and host homeowner Salangsang testified they were unarmed and proceeding slowly with dimmed headlights when gunmen, positioned inside Naron’s yard an Case Digest (G.R. No. 150711) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioners: Law enforcers and barangay officials—Salvador Yapyuco, Jr., Generoso Cunanan, Jr., Ernesto Puno (INP/PNP members), Mario D. Reyes, Andres S. Reyes, Virgilio A. Manguerra (CHDF members/barangay captains).
- Respondents: Sandiganbayan (trial court) and the People of the Philippines.
- Shooting Incident (April 5, 1988, Barangay Quebiawan, San Fernando, Pampanga)
- Victims: Leodevince Licup (died April 7), Noel Villanueva (survived multiple gunshot wounds), four other passengers unharmed.
- Circumstances: Petitioners, responding to a tip about armed rebels, took positions along a curve and opened fire at a green Toyota Tamaraw jeepney. Evidence included eyewitnesses (Flores, Salangsang, Villanueva), ballistics (11 bullet holes in jeepney), medico-legal reports, and administrative‐case documents.
- Trial Proceedings
- Charges filed in three Informations:
- No. 16612—Murder (resulted in homicide conviction)
- No. 16613—Frustrated murder (acquitted)
- No. 16614—Multiple attempted murder (resulted in attempted homicide conviction)
- Evidence: Direct testimony, sketches, ballistics and medical reports, extrajudicial/joint counter-affidavits, petitioners’ testimony and NAPOLCOM administrative records.
- Sandiganbayan Decision (June 30, 1995): Found petitioners guilty as co-principals of homicide (Licup) and attempted homicide (Villanueva); acquitted them of attempted murder.
Issues:
- Justification and Defenses
- Whether petitioners were in lawful performance of duty (Art. 11(5), Revised Penal Code).
- Whether a mistake of fact (belief victims were armed NPAs) negates criminal intent.
- Criminal Liability
- Whether conspiracy and co-principal liability were proved beyond reasonable doubt.
- Whether petitioners’ acts show intent to kill or only reckless imprudence.
- Penalty and Damages
- Proper classification and application of the Indeterminate Sentence Law.
- Appropriate quantum for actual, moral, and exemplary damages.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)