327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Was a man justified in hacking another man 17 times to death,
claiming self-defense, when multiple assailants were involved?
People of the Philippines vs. Reynaldo Pigar y Ambayanan
@ "Jerry" and Reynaldo Pigar y Codilla @ "Lawlaw", G.R.
No. 247658, February 17, 2020
Facts of the Case:
Reynaldo Pigar y Ambayanan (Jerry) and Reynaldo Pigar y
Codilla (Lawlaw) were convicted of murder by the Regional Trial Court and the
Court of Appeals for the brutal killing of Feliciano Garces Sr. The incident
occurred on August 17, 2009, in Capoocan, Leyte, after a series of
confrontations involving Edgardo Garces, the victim's son, and Roy Pigar,
Jerry’s brother. Following a quarrel between Edgardo and Roy, Jerry, Lawlaw,
and others, allegedly armed with bolos and bamboo spears, attacked Feliciano Sr.
at his home.
According to the prosecution, the assailants surrounded the
house and hacked Feliciano Sr. repeatedly after he emerged, having been
disturbed from his sleep by the ruckus outside. Feliciano Sr. was a frail
52-year-old man at the time. Dr. Bibiana Cardente, the municipal health
officer, confirmed the victim sustained 17 stab wounds, five of which were
fatal.
The defense argued that Jerry was merely defending himself,
claiming that Feliciano Sr. attacked him first with a weapon, injuring him.
Jerry admitted to hacking Feliciano Sr. multiple times in retaliation. Lawlaw
denied any involvement, maintaining he was at work in a bakery at the time of
the incident.
The Regional Trial Court found Jerry and Lawlaw guilty of
murder. It appreciated the qualifying circumstance of abuse of superior
strength and sentenced both to reclusion perpetua without parole
eligibility. The Court of Appeals affirmed the ruling.
Primary Issue in the Supreme Court:
Did the Court of Appeals err in affirming the appellants'
conviction for murder, particularly given the alleged inconsistencies in
witness testimonies and the claim of self-defense?
Ruling of the Supreme Court:
The Supreme Court affirmed the conviction but with modification.
It held that:
- The
positive identification of Jerry and Lawlaw as assailants by witnesses
Marietta and Edgardo Garces was credible, despite minor inconsistencies in
the timeline and exact locations of the attack.
- Jerry’s
claim of self-defense was insufficient. The evidence, including his
admission of intending to harm Edgardo, indicated a premeditated attack on
Feliciano Sr. Furthermore, Jerry’s claim that Feliciano Sr. attacked him
first was unconvincing given the overwhelming evidence that nine men
attacked a frail, slow-moving 52-year-old.
- Lawlaw’s
defense of alibi failed because he was placed at the scene, and the bakery
where he claimed to be was in the same locality.
- Abuse
of superior strength was established, as nine men attacked the defenseless
victim. However, the trial court improperly considered the ordinary
aggravating circumstance of dwelling, as it was not explicitly alleged in
the information.
As a result, the penalty imposed was modified to reclusion
perpetua without parole, and the damages were updated in line with prevailing
jurisprudence.
Dispositive Portion:
"Appellants Reynaldo Pigar y Ambayanan alias 'Jerry'
and Reynaldo Pigar y Codilla alias 'Lawlaw' are GUILTY of Murder under Article
248 of the Revised Penal Code. They are each sentenced to reclusion perpetua.
They are further ordered to PAY the heirs of Feliciano S. Garces Sr. the
following monetary awards:
- Php
75,000.00 as civil indemnity;
- Php
75,000.00 as moral damages;
- Php
75,000.00 as exemplary damages; and
- Php
50,000.00 as temperate damages.
All monetary awards shall earn six percent (6%) interest per
annum from finality of this decision until fully paid."
SO ORDERED.
In cases of multiple assailants, is it ever justifiable for
one person to claim self-defense after brutally attacking someone, especially
when they are outnumbered and overpowered?
Important Doctrines:
- Self-defense
requires proof of unlawful aggression – Mere claims are not
sufficient, especially when the evidence suggests an overwhelming attack
rather than a defensive action.
- Abuse
of superior strength as a qualifying circumstance – When multiple
assailants attack a weaker victim, this can elevate a killing to murder,
even if the assailants claim to have been provoked.
- Denial
and alibi must be airtight – These defenses are weak unless clearly
substantiated, especially if the accused is placed at the scene of the
crime.
This case falls under Criminal Law.
From <https://chatgpt.com/c/66eec0ad-c730-800a-a2b9-e720b2508ea2>
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🎓 INTRODUCTION FROM A
PHILIPPINE LAW PROFESSOR 🎓
Welcome to this jurisprudence-focused content designed to
help law students, bar examinees (baristas), and legal enthusiasts
understand and recall key doctrines from Philippine case law.
In this video, we focus on the landmark criminal case of:
People of the Philippines vs. Reynaldo Pigar y Ambayanan
@ "Jerry" and Reynaldo Pigar y Codilla @ "Lawlaw"
G.R. No. 247658 | Promulgated: February 17, 2020
⚖️ Nature of the Case:
Criminal Law – Murder under Article 248 of the Revised Penal Code.
Parties: The People of the Philippines
(Plaintiff-Appellee) vs. Reynaldo Pigar & Reynaldo Codilla
(Accused-Appellants).
📝 Brief Summary:
In Capoocan, Leyte, an elderly man was brutally stabbed 17
times by a group including the appellants. The RTC and CA found them guilty of
murder due to abuse of superior strength. The Supreme Court affirmed the
conviction with modifications in penalties and monetary awards.
💭 Thought-Provoking
Question:
Can an overwhelming group assault still be justified by one
person's claim of self-defense?
📚 10 Important Doctrines
from the Case (People v. Pigar, G.R. No. 247658):
- Positive
Identification over Denial
Eyewitness testimony by Marietta and Edgardo Garces identifying the accused prevails over uncorroborated denials.
📖 [See Supreme Court ruling reaffirming trial court findings] - Self-Defense
Must Be Proven by Clear Evidence
A claim of self-defense must be backed by credible, physical, and consistent evidence, not mere allegations.
📖 [Supreme Court: Self-defense requires unlawful aggression] - Abuse
of Superior Strength as Qualifying Circumstance
When attackers vastly outnumber a slow, frail victim, abuse of superior strength qualifies the killing as murder.
📖 [Citing Article 248, Revised Penal Code] - Inconsistencies
on Minor Details Are Not Fatal
Discrepancies in minor details do not discredit credible testimonies on material facts.
📖 [Citing People v. Pulgo, 813 Phil. 205] - Conspiracy
Equates to Equal Liability
In conspiracy, the act of one is the act of all, even if not all delivered fatal blows.
📖 [People v. Lababo, G.R. No. 234651] - Alibi
Must Show Physical Impossibility to Be at Crime Scene
An alibi fails unless it proves that the accused could not have been physically present.
📖 [Citing People v. Ambatang, 808 Phil. 236] - No
Treachery Without Surprise Attack
Treachery does not apply when the victim is forewarned or expects possible harm.
📖 [People v. Moreno, G.R. No. 217889] - Dwelling
Must Be Alleged to Be Appreciated
An aggravating circumstance like “dwelling” cannot be considered if not alleged in the information.
📖 [Revised Rules of Court, Rule 110, Sec. 8] - Moral
and Exemplary Damages Require No Proof
These damages are awarded in murder cases as a matter of course, without need for detailed evidence.
📖 [People v. Jugueta, 783 Phil. 806] - Damages
Earn Legal Interest Until Fully Paid
All damages awarded by the Court shall earn 6% legal interest per annum from finality until full payment.
📖 [Based on Jugueta and Supreme Court practice]
🔍 FAQs:
Q1: What made the killing classified as murder?
A: Abuse of superior strength – 9 men against a
frail, slow-moving victim.
Q2: Was treachery appreciated?
A: No. The victim was forewarned by prior aggression.
Q3: Why was dwelling not considered?
A: It was not alleged in the information, violating
Rule 110.
Q4: What’s the minimum requirement for conspiracy?
A: Even moral support or acting as a lookout during
the crime suffices.
Q5: Can self-defense still succeed when fatal
blows are repeated?
A: Not when the force used is excessive and
unprovoked, especially in group assaults.
📌 Case Title: People
of the Philippines vs. Reynaldo Pigar y Ambayanan and Reynaldo Codilla
G.R. No. 247658 | Promulgated: February 17, 2020
📢 DISCLAIMER: This
is for educational purposes only. Content may not be infallible. Created
using premium Artificial Intelligence.
From <https://chatgpt.com/c/66eec0ad-c730-800a-a2b9-e720b2508ea2>
🎓 Welcome, future lawyers and
legal thinkers! This quizzer is based on a recent Supreme Court ruling
involving a criminal case for murder, designed to challenge your understanding
of legal doctrines and application of facts.
The case in focus is:
People of the Philippines vs. Reynaldo
Pigar y Ambayanan @ “Jerry” and Reynaldo Pigar y Codilla @ “Lawlaw”
G.R. No. 247658, Promulgated: February17, 2020
🧾 Nature of the Case: Criminal
Law – Murder
👥 Parties: The People of the
Philippines (Plaintiff-Appellee) vs. Reynaldo Pigar & Reynaldo Codilla
(Accused-Appellants)
📝 Brief Case Summary:
Feliciano Garces Sr., a frail and
slow-moving 52-year-old man, was fatally stabbed 17 times in his home by a
group of men, including the two accused. The defense argued self-defense and
alibi. The RTC and the CA found the accused guilty of murder for having abused
superior strength. The Supreme Court affirmed the conviction, with a modification
of the penalties and monetary awards, and clarified several doctrines,
including conspiracy, positive identification, and the necessity of alleging
aggravating circumstances in the information.
✅ The answer key will be revealed at the
end of the video – so stay sharp and engaged throughout!
🔍 QUIZZER: HOTS (Higher Order
Thinking Skills) – EASY DIFFICULTY
1. What factor most strongly influenced
the Court's decision to classify the killing as murder rather than homicide?
A. The age of the victim
B. The number of stab wounds
C. The presence of conspiracy
D. The abuse of superior strength
2. Which of the following best describes
the Court's view on inconsistencies in minor details in witness testimonies?
A. Grounds for automatic acquittal
B. Evidence of perjury
C. Normal and not necessarily fatal to
credibility
D. Strong indication of falsehood
3. How did the Court treat the alibi
presented by one of the accused?
A. Acceptable because it was under oath
B. Rejected due to physical proximity to
the crime scene
C. Granted because no motive was shown
D. Accepted because it was corroborated
by another accused
4. What is the significance of “positive
identification” by witnesses according to the Court?
A. It must be corroborated by documents
B. It overcomes denial and alibi
C. It is required only in theft cases
D. It is weaker than a confession
5. What was the Court’s ruling on the
participation of accused who did not deliver fatal blows?
A. They were acquitted
B. They were considered accessories
C. They were equally liable under
conspiracy
D. They were convicted of frustrated
murder
6. Which of the following was not
appreciated as an aggravating circumstance in this case due to absence in the
charge sheet?
A. Abuse of superior strength
B. Dwelling
C. Evident premeditation
D. Use of deadly weapons
7. Why did the Court reject the defense
of self-defense?
A. The accused presented no medical
evidence
B. The victim was found with no weapon
C. The number of assailants made the
claim unbelievable
D. The accused confessed to the crime
8. What principle did the Court affirm
regarding human behavior during traumatic events?
A. Witnesses should intervene
B. Reactions are unpredictable
C. Witnesses must always testify
immediately
D. Silence implies guilt
9. What was one reason the Court
maintained the credibility of the eyewitnesses?
A. They were related to the accused
B. They were the first to arrive at the
scene
C. Their testimonies were consistent on
material points
D. They admitted to inconsistencies
10. What was the final penalty imposed
by the Supreme Court?
A. Life imprisonment without damages
B. Reclusion perpetua with damages
C. Acquittal of one accused
D. Death penalty reinstated
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