Sunday, April 21, 2013

Pp vs Lawas: a metamorphosis


In my last post I mentioned in passing the problem  of referring to an unreported SC decision.

Such is the case of People vs Lawas which is listed down as G.R. Nos. L-7618-7620 and supposedly to be found in 97 Phil. 975 but which is nowhere to be found in Lawphil or in Chan Robles.

The earliest citation available on the internet would be Pp vs Remollino, GR No. L-14008 which was decided by Justice Paredes on Sept. 30, 1960. The citation does not mention any personalities:


In Pp vs Caldito, GR 78432-33, Feb. 9, 1990 the characters involved in the case emerged:


In Pp vs Palomar, GR 108183-85, Aug 21, 1997, Justice Panganiban provided additional identification of the Home Guards:


But in Pp vs Elarcosa, GR No. 186539, June 29, 2010 even Justice Velasco seemed to be confused by the personalities:

Such is the problem with unreported decisions.

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