CASE DIGEST 101: TIPS ON HOW TO CREATE A CASE DIGEST!!!
By : ATTY. MEYNARD H. MAGSINO
1. Read the case in the ORIGINAL. GET A FULL TEXT COPY OF THE
CASE! You can’t effectively digest what you haven’t read.
2. Reading the case takes some time. As you read the case, take note
of which facts and issues you’ll include in the digest.
3. Start your digest with the title of the case, citation, date, and
ponente (SC justice who wrote the majority opinion).
4. Your digest must have: FACTS, ISSUE(S), and RULING sections.
5. FACTS. Make sure that there is coherence. You’re telling a story of
how this case came about. You have to include how it moved up
the judicial hierarchy from RTC to CA to SC.
6. ISSUE. The “whether or not x x x” is the easiest to formulate. Some
cases have just one issue, some have many. Make sure that the
issue is related to the topics to be discussed.
7. RULING. How did the court resolve the issue? What was the
reasoning behind the ruling?
Sample Case Digest
G.R. No. 182549, January 20, 2009
People of the Philippines vs .Sergio Lagarde
Ponente: Velasco, Jr.
Facts: Lagarde was charged with rape in an information stating that: On December
27, 2001 in Leyte, deliberate and of use of force and intimidation rape an 11 year-
old. Upon arraignment, Lagarde pleaded not guilty.
During trial, prosecution presented testimony of the minor and her the doctor who
examined her after the incident. Defense presented Lagarde denial contending that
he didn't left the house of Lolita during the fiesta celebration, that he had a drinking
spree with the other visitors.
The RTC found AAA’s testimony credible, noting that at her age, it is inconceivable
for her to concoct a tale of having been raped. Her accusation, according to the RTC,
was supported by medical findings that she was indeed sexually abused. The lower
court dismissed accused-appellant’s denial and alibi. Lolita’s testimony was likewise
disbelieved not only because she was related to accused-appellant but also because
she herself was busy drinking tuba in another part of the house. She could not
categorically say, the RTC added, that accused-appellant did not leave his seat and
molest AAA.
The appellate court upheld the trial court’s findings of fact and judgment of
conviction. With regard to the penalty, however, the CA ruled that the trial court
erred when it imposed the death sentence on the basis of the following aggravating
circumstances: minority, use of bladed weapon, and uninhabited place.
Issues: (1) the court gravely erred in finding the guilt of the accused (2) the court
gravely erred in imposing upon the accused the penalty of reclusion perpetua.
Ruling: Appeal has no merit.
In rape cases, courts are governed by the following principles: (1) an accusation of
rape can be made with facility; it is difficult to prove but more difficult for the person
accused, though innocent, to disprove; (2) due to the nature of the crime of rape in
which only two persons are usually involved, the testimony of the complainant must
be scrutinized with extreme caution; and (3) the evidence for the prosecution must
stand or fall on its own merits and cannot be allowed to draw strength from the
weakness of the evidence for the defense. Due to the nature of this crime, only the
complainant can testify against the assailant. Accordingly, conviction for rape may be
solely based on the complainant’s testimony provided it is credible, natural,
convincing, and consistent with human nature and the normal course of things.
The trial court observed that AAA’s testimony was credible, straightforward, clear,
and convincing. She ably identified accused-appellant as her attacker and described
in detail how she was sexually assaulted. There is no reason a child would fabricate
such a serious accusation such as rape and risk public humiliation if not to seek
justice. It is for this reason that testimonies of child-victims are normally given full
weight and credence, since when minors say they were raped, they say in effect all
that is necessary to show that rape was committed.
The victim’s credibility is further bolstered by the immediate reporting of the incident
to her mother and subsequently to the authorities. Moreover, the medical findings of
Drs. Oyzon and Palencia-Jadloc established the fact that complainant had sexual
intercourse. Accused-appellant, on the other hand, could only offer denial and alibi
as defenses. His alibi that he spent the afternoon drinking with other visitors does
not deserve merit since he was present in the same house where the victim was.
The appellate court correctly ruled that the use of a bladed weapon and uninhabited
place are not circumstances that would call for the imposition of the death
penalty. The victim’s minority does not also qualify the offense to merit the death
penalty. To warrant a death sentence, the victim must be under seven (7) years of
age.
GENRAL DIRECTION: Write your digest in Blue Notebook. Your Notebook Digest
will be submitted during the examination week. Failure to comply would merit a
deduction in the computation of your grades.
Create a digest of the Following cases:
1. PP vs Clopino, GR No. 117322, May 21, 1998
2. Valenzuela vs People GR No. 160188 June 21, 2007
3. Cruz vs CA GR No. 108738 June 17, 1992
4. US vs Ah Chong GR No. 5272 March 19, 1910
5. People Vs Flora GR No. 125909 June 23, 2000
6. People vs Pinto GR No. 39519 November 21, 1991
7. People vs Acuram GR No. 117954, April 27, 2000
8. Intod vs CA GR No. 103119 October 21, 1992
9. PP vs Albacin GR No. 133918 September 13, 2000
10. People vs Tabuso GR No. 113708 October 26, 1999
