G.R. No. L-204 - People vs. Cornel

The case involves the People of the Philippines prosecuting Gerardo Cornel for homicide.
The trial court of the Court of First Instance of Albay convicted the defendant and imposed an indeterminate prison term ranging from 8 years and 1 day to 14 years, 8 months and 1 day, along with accessory penalties.
The judgment also required the indemnification of the heirs of the deceased, Fabian Burac, in the sum of P2,000, and payment of costs.

On the afternoon of June 8, 1945, at about 6 o’clock, Trinidad Coral testified that she witnessed the defendant assault her deceased husband, Fabian Burac, with a bolo as the latter was descending the stairs of his house in the barrio of San Miguel, municipality of Tabaco, Province of Albay.
According to Trinidad Coral’s testimony:

The defendant suddenly attacked Fabian Burac with a bolo.
After Fabian was wounded in the forehead and fell, the defendant hurled a stone that struck Fabian’s right clavicle.
The defendant then fled in the direction of his house.

The trial court gave full credit to Trinidad Coral’s positive and direct testimony, noting that her ability to observe and hear the events was significant, particularly since she knew the defendant well.

Another witness, Caspara Bendicio, testified that when she inquired about the incident, Fabian Burac stated that he had been attacked by the defendant.

This statement, offered under the rule of res gestae, was accepted despite the defendant’s argument on its admissibility.

The prosecution presented additional evidence showing that the defendant had been prosecuted for physical injuries even before Fabian’s subsequent death.

Dr. Mariano Cruel, a government witness, described the wound on Fabian Burac’s forehead as “an incised vertical wound extending from a little above the middle of the eyebrows down to the lower root of the nose” which involved fracturing the frontal and nasal bones.
Despite the defendant’s contention that the wound might have been caused by a heavy stone or irregular hard object, the court held that such alternative theories were conjectural given the clear eyewitness account of a criminal assault.
The death of Fabian Burac was primarily attributed to tetanus induced by the infected wound, as observed and certified by Dr. Cruel.

When Fabian reported for treatment on June 15, 1945, signs of tetanus were manifest, prompting the prescription of anti-tetanic serum which, due to unavailability, was not administered.

The defendant advanced an alibi arguing that he was in Tabaco, Albay from 5 p.m. on June 8 until the morning of June 9, a claim put to test by the credible eyewitness testimony.
Additionally, his counsel argued the possibility of mistaken identification by Trinidad Coral and presented an alternative medical theory regarding the nature of the wound.
The court, however, dismissed these arguments due to the strength and consistency of the evidence presented against the defendant.

Circumstantial evidence suggested a motive for the crime: Fabian Burac had previously arrested and threatened the defendant during the Japanese occupation.
This historical animosity provided an additional context and potential motive for the unlawful act committed by the defendant.

Whether the evidence presented, particularly the eyewitness testimony of Trinidad Coral and corroborative statement by Caspara Bendicio, was adequate to establish the defendant’s identity as the assailant.
Whether doubts raised by the defense regarding possible mistaken identification could undermine the reliability of the prosecution’s evidence.

Whether the wound on Fabian Burac’s forehead, as described by Dr. Cruel, could have been produced by an alternative weapon or object, thereby challenging the prosecution’s narrative of the assault.
Whether the alternative explanation of the wound was sufficiently substantiated or remained conjectural in the face of direct eyewitness testimony.

Whether the death of Fabian Burac, certified as a result of tetanus from the infected wound, could be conclusively linked to the defendant’s act of assault.
Whether the natural consequences of the defendant’s unlawful act should extend to responsibility for the subsequent fatality.

Whether the defendant’s claim of being in Tabaco during the critical period was credible or outweighed by the direct evidence of his involvement in the incident.