Case Digest (G.R. No. 244071)
Facts:
This is Shiela Marie B. Cafranca and Ma. Josephine B. Cafranca v. People and Raymark Velasco @ "Mamark" and Carlito Orbiso y Abique @ "Carla" v. People, G.R. Nos. 244071 and 244208, promulgated May 15, 2024, the Supreme Court First Division, Zalameda, J., writing for the Court.Petitioners — Shiela Marie Cafranca (Shiela), Ma. Josephine Cafranca (Majo), Raymark Velasco (Mamark), and Carlito Orbiso (Carla) — were criminally charged by Information with homicidal liability under Article 249 in relation to Article 4(1) of the Revised Penal Code for the death of 76‑year‑old Oscar Duran on or about March 23, 2011 in Muntinlupa City. The Information alleged that petitioners conspired, attempted to hit Oscar with a steel chair, and uttered invective causing irritation or annoyance, which directly resulted in Oscar suffering a cardiorespiratory arrest.
At the Regional Trial Court (Branch 276, Muntinlupa City), petitioners pleaded not guilty and went to trial. The prosecution presented eyewitnesses (Ruby Ann Ocop, Raynor Simbolas, Jenette Deuna), medical witnesses (Dr. Rene Retuerma, Dr. Rowena Tan), and Oscar’s daughter to prove that verbal and physical confrontations preceded Oscar’s collapse and death. The defense testified that petitioners were reacting to Oscar’s alleged aggressive conduct toward Shiela’s dog and that any physical contact was defensive or minimal; they produced medical reports of minor injuries to Shiela and Carla.
On May 23, 2016, the RTC convicted all four petitioners of homicide under Article 249 in relation to Article 4(1), finding that petitioners’ threats and ill‑treatment proximately caused Oscar’s death; it applied mitigating circumstances and imposed an indeterminate term, and ordered monetary awards to the heirs. The Court of Appeals (Special Fifteenth Division) affirmed the RTC’s decision on February 28, 2018 (modifying the interest on damages to 6% per annum), and denied petitioners’ motion for reconsideration on January 15, 2019.
Petitioners separately filed petitions for review on certiorari under Rule 45, which this Court consolidated by resolution dat...(Subscriber-Only)
Issues:
- Under the limited scope of Rule 45, should this Court re‑examine the factual findings of the trial court and Court of Appeals in these consolidated petitions?
- Did the prosecution prove beyond reasonable doubt the elements of Article 4(1) of the Revised Penal Code and therefore sustain petitioners’ convictions for homicide under Article 249; if not, are there lesser or other offenses prop...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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