Case Analysis of People vs Escober

G.R. No. L-69564 January 29, 1988

Juan Escober is a Security guard at Bee Seng Electrical Supply

Balintawak, Quezon City, owned by Vicente and Lina Chua. One of the alleged
co-conspirators is Amadeo Abuyen alias Roberto Alorte who was formerly a co-
security guard of appellant Juan Escober at the same corporation. Abuyen
together with respondent Punzalan and other companion went to the said
company. As Escober recognized Abuyen, he let them get inside the
compoundand a gunshot was fired. Thereafter, Abuyen and Punzalan fled,
followed by Escober. Vicente Chua saw his two children mortally wounded and
observed that several items were missing. The accused-appellants Juan
Escober, Macario Punzalan Jr., Peter Doe, Richard Doe and Juan Doe were
charged with the crime of Robbery with Homicide before the Regional Trial
Court of Quezon City. However, accused-appellant Juan nEscober asserts that
said decision is null and void for it does not conform to the requirement of
section 9, article X of the 1973 constitution that it was endered evenbefore all
the stenographic notes of the proceedings had been transcribed.

ISSUES:
Whether or not the said decision is null and void

HELD:
Yes. The said decision is null and void for its does not conform with the
requirement of Section 9, Article X of the 1973 Constitution and that it was
rendered even before all the stenographic notes of the proceedings had been
transcribed.
Section 9, Article X of the 1973 Constitution directed that: “Every decision of a
court shall clearly and distinctly state the facts and the law on which it is
based x x x.”
The decision failed to conform to the requirements of Section 9, Article X
of the 1973 Constitution. The inadequacy stems primarily from the respondent
judge’s tendency to generalize and to form conclusions without detailing the
facts from which such conclusions are deduced.

Without particularization of the evidence, testimonial or documentary,

upon which the findings of facts are based, it is practically impossible for the
appellate court to determine whether or not such findings were sufficiently and
logically supported by the evidence relied upon by the trial court.