Case Summary (G.R. No. 201310)
Procedural Background
Marasigan contested several decisions from lower courts and the Department of Justice (DOJ). The DOJ's initial ruling, issued by Undersecretary Linda L. Malenab-Hornilla on September 2, 2009, favored Marasigan, directing the filing of attempted murder charges against the respondents. However, that decision was reversed on February 8, 2010, by Secretary Agnes VST Devanadera, who determined that only Robert Calilan could be charged with less serious physical injuries.
Allegations and Incident Details
On the night of the incident, while Marasigan was walking home, he was assaulted by Fuentes and others, including Calilan and Lindo. Fuentes allegedly threw an object at him, which led to a physical confrontation involving multiple assailants. Witnesses provided testimony confirming that the assault involved attempts to cause serious harm, including the use of a hollow block intended to strike Marasigan's head.
Initial Prosecutorial Findings
Assistant Provincial Prosecutor Christopher R. Serrano conducted a preliminary investigation and concluded that there was insufficient evidence to support a murder charge, instead recommending less serious physical injuries against Fuentes and Calilan, while clearing Lindo of any liability. Marasigan appealed this decision, arguing for attempted murder charges based on the severity of the assault and the evidence of conspiracy among the assailants.
DOJ’s Reversal and Legal Analysis
Undersecretary Malenab-Hornilla initially found enough grounds to charge the respondents with attempted murder, distinguishing the nature of their actions as indicative of a design to kill, which was interrupted due to witness intervention. However, Secretary Devanadera’s later ruling—upholding Serrano’s assessment—relied too heavily on the medico-legal findings without adequately considering the broader context of the incident and the testimonies supporting an intent to kill.
Court of Appeals Decision
The Court of Appeals dismissed Marasigan’s petition for certiorari, affirming Secretary Devanadera's resolution that concluded no sufficient evidence existed to charge the respondents with anything beyond less serious physical injuries, which prompted Marasigan to appeal to the Supreme Court.
Supreme Court Findings
The Supreme Court found that both Secretary Devanadera and Prosecutor Serrano had misunderstood the facts, particularly regarding the threshold for probable cause in attempted murder. The reasonings hinged on the fact that probable cause merely required a well-founded belief that a crime was committed, n
...continue readingCase Syllabus (G.R. No. 201310)
Case Overview
- The case involves a petition for review on certiorari filed by Mark Reynald Marasigan against Reginald Fuentes, Robert Calilan, and Alain Delon Lindo.
- The petition challenges the decisions of the Court of Appeals, specifically the August 19, 2011 Decision and the February 21, 2012 Resolution, which dismissed Marasigan's petition and affirmed the earlier resolution by the Department of Justice (DOJ).
- The case centers around allegations of attempted murder and less serious physical injuries stemming from an altercation that occurred on December 20, 2006.
Factual Background
- Marasigan alleged that on December 20, 2006, while walking home, Fuentes threw an object at him, leading to an encounter where he was assaulted by Fuentes, Calilan, and Lindo.
- Witnesses confirmed that Fuentes initiated the assault, striking Marasigan and attempting to use a hollow block as a weapon.
- The altercation escalated with multiple individuals participating, and Marasigan sustained injuries that required medical examination and formal complaints were lodged.
Procedural History
- Assistant Provincial Prosecutor Serrano initially found probable cause only for less serious physical injuries against Fuentes and Calilan, clearing Lindo of liability.
- Marasigan appealed this resolution to the DOJ, arguing that the evidence