Case Digest (G.R. No. 171951)
Facts:
Amado Alvarado Garcia v. People of the Philippines, G.R. No. 171951, August 28, 2009, Supreme Court Second Division, Quisumbing, J., writing for the Court.Petitioner Amado Garcia was charged in an Information dated February 10, 2000 with murder (Article 248, as amended by R.A. 7659, later treated by the courts as homicide under Article 249) for acts allegedly committed on September 29, 1999 in Aparri, Cagayan. He pleaded not guilty and trial followed before the Regional Trial Court (RTC), Branch 9, Aparri, presided over initially by Judge Conrado F. Manauis; Judge Andres Q. Cipriano later prepared the judgment after Judge Manauis recused. The RTC found petitioner guilty beyond reasonable doubt of homicide and sentenced him under the Indeterminate Sentence Law to an indeterminate term (ten years prision mayor as minimum to fourteen years and eight months reclusion temporal as maximum), and ordered payment of civil damages, funeral expenses and moral damages.
On appeal, the Court of Appeals (CA) in CA-G.R.-CR No. 27544 affirmed the RTC decision in a December 20, 2005 Decision, and denied petitioner's motion for reconsideration by Resolution dated March 13, 2006. Petitioner then filed a petition for review on certiorari under Rule 45 of the Rules of Court to the Supreme Court raising factual and legal contentions: he denied or minimized his role in assaulting the victim Manuel K. Chy (implicating others instead), argued that Chy’s death was due to myocardial infarction (a non-violent cause) and not the beating, contended that the judge who penned the decision did not hear the trial testimony and thus credibility findings were tainted, and claimed reasonable doubt merited acquittal.
The evidentiary record shows several drinking episodes involving petitioner and companions and an escalating exchange with Chy culminating in petitioner striking Chy (including punching and hitting with a beer bottle); Chy ran home, was found unconscious, and died shortly thereafter. The autopsy listed contusions and a lacerated lip and concluded cause of death as myocardial infarction with findings of coronary arteriosclerosis and mild myocardial fibrosis and pulmonary edema. Medical witnesses testified that emotional shock/excitement from the mauling could, in a person with pre-existing arteriosclerosis and myocardial fibrosis, precipitate coronary occlus...(Pro-only)
Issues:
- Does the fact that the judge who authored the RTC decision did not preside over the entire trial invalidate the RTC's credibility findings and warrant reversal?
- Did the appellate court err in affirming the finding that petitioner inflicted the injuries on Manuel Chy?
- Is petitioner criminally liable for Chy’s death although the autopsy lists myocardial infarction as cause of death and the decedent had pre-existing heart disease?
- Was petitioner entitled to...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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