Case Digest (G.R. No. 226335) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Amado Alvarado Garcia v. People of the Philippines, petitioner Amado Garcia was charged with murder under Article 248 of the Revised Penal Code (as amended by R.A. No. 7659) for the September 29, 1999 mauling of one Manuel K. Chy in Aparri, Cagayan. The Information alleged that, armed with a bottle and acting with evident premeditation and treachery, Garcia assaulted Chy, inflicting injuries that proved fatal. At trial, witnesses testified that petitioner and companions held successive drinking sprees on September 26, 28, and 29, during which Chy twice asked them to lower their videoke noise. Each time Garcia responded with Ilocano threats: “This Manny is arrogant; I will lay a hand on him,” and later, “I will finish him off today.” On the afternoon of September 29, at Aurelia Esquibel’s store (Chy’s sister), Garcia summoned Chy, struck him with fists and then with a beer bottle on the nape. Chy collapsed, ran home, summoned the police and collapsed again, salivated, and Case Digest (G.R. No. 226335) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Charge
- On February 10, 2000, the Provincial Prosecutor filed an information against Amado Garcia @ Manding for Murder under Article 248, RPC, as amended, alleging that on September 29, 1999 in Aparri, Cagayan, petitioner, armed with a bottle, with intent to kill, and with treachery and evident premeditation, assaulted Manuel K. Chy, inflicting fatal injuries.
- Petitioner pleaded not guilty; trial ensued before the Regional Trial Court (RTC), Branch 9, Aparri.
- Antecedent Confrontations
- September 26, 1999 – At around 11:00 a.m., petitioner and companions held a drinking spree beside Chy’s house; at 7:00 p.m., Chy twice requested they lower the videoke noise. Petitioner, angered, threatened Chy in Ilocano.
- September 28, 1999 – During a wedding celebration, Chy’s sister warned the group; petitioner again expressed intent to “not let Manny live long.”
- September 29, 1999 – At noon, petitioner vowed “to finish” Chy while recalling prior confrontations.
- Assault and Death of Victim
- Late afternoon of September 29, 1999, petitioner and his group summoned Chy from his sister’s store; petitioner first punched Chy in the face, then struck him on the nape with a beer bottle. Chy fled home, complained of breathing difficulty, and was found unconscious; he was pronounced dead on arrival at the hospital.
- Autopsy revealed contusions and a laceration, mild myocardial fibrosis, 30% coronary artery occlusion, pulmonary edema and hemorrhage. Cause of death was myocardial infarction.
- Proceedings Below
- RTC convicted petitioner of homicide under Article 249, RPC, sentencing him to an indeterminate term of 10 years Prision Mayor (minimum) to 14 years and 8 months Reclusion Temporal (maximum), and ordering indemnities:
- P50,000 civil; P200,000 funeral; P300,000 moral; P332,000 loss of earning capacity.
- The Court of Appeals affirmed the conviction and sentence in a December 20, 2005 Decision and denied reconsideration March 13, 2006. Petitioner appealed to the Supreme Court, raising four grounds challenging his responsibility for the death, the causal link to myocardial infarction, the heart failure’s origin, and reasonable doubt.
Issues:
- Whether petitioner inflicted the injuries on Chy and is liable for his death.
- Whether myocardial infarction, a non-violent cause, breaks the causal nexus between the assault and death.
- Whether Chy’s heart failure was due to fright or shock from the maltreatment.
- Whether reasonable doubt exists warranting petitioner’s acquittal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)