G.R. No. 45419 - Santos vs. People

The appellant, Natalio Ilustre, was charged with homicide for allegedly dealing a fatal blow with his closed fist to Juan Magsino on or about June 24, 1929, in Balayan, Batangas.
The blow was specifically to the right hypochondriac region, bruising the liver, causing internal hemorrhage, and resulting in the death of Magsino.
The crime was charged under the law prohibiting unlawful and felonious homicide.

The Court of First Instance of Batangas found the defendant guilty.
Due to absence of intent to commit so grave an evil as death, the defendant was sentenced to twelve years and one day of reclusion temporal, ordered to pay ₱1,000 indemnity to the victim’s family, and costs.
Defendant appealed the sentence.

Denial that the appellant hit Magsino in the right hypochondriac region causing liver bruising.
Challenge on causation, arguing that even if the blow caused injury, it was not the direct cause of death.
Claim of doubt as to real cause of death, suggesting conviction for a lesser misdemeanor instead.
Argument that the act was without criminal intent, meriting acquittal.
Appeal for benefit of the reasonable doubt to acquit the defendant.

Occasion: June 24, 1929, feast day with a procession in Canlurangbayan, Balayan.
Natalio Ilustre was the person in charge of preventing the populace from consuming all of a roasted pig carried in the procession.
Juan Magsino, described as delicate and suffering from incipient tuberculosis, attempted to take a piece of the barbecued pig.
The defendant ran after him and struck him with a fist, knocking him down.
Magsino became ill shortly afterwards and died around 3 pm the same day.

Autopsy conducted by Drs. Jose Ilagan, Antonio Agoncillo, and Hermenegildo del Castillo.
Findings:

Bruising on the anterior right lobe of the liver.
Internal hemorrhage indicated by ecchymotic spots in right epigastric region and hemorrhagic peritoneum.
Sanguineous fluid in the abdominal cavity.
Presence of miliary granules in lungs indicating incipient tuberculosis.
Heart somewhat dilated but with normal valves.

Dr. Ilagan and Dr. Agoncillo opined death was caused by contusion of liver and internal hemorrhage, dismissing tuberculosis and heart disease as causes.
Dr. del Castillo did not reach a definite conclusion about cause of death.
Dr. Sixto Roxas, provincial hospital director, reviewed findings:

Agreed a blow could cause death but deemed death within five hours rare given Magsino’s condition.
Recognized internal hemorrhage caused by blow contributed significantly to death.
Considered it “natural” that the blow’s shock was the cause of death.

Whether the appellant inflicted the fatal blow causing injury to the right hypochondriac region of Juan Magsino.
Whether the liver contusion and internal hemorrhage caused by the blow was the direct cause of the victim’s death.
Whether doubt as to the actual cause of death justifies a conviction for a lesser offense or acquittal.
Whether the absence of criminal intent absolves the appellant from liability.
Whether the benefit of reasonable doubt should have been applied to acquit the defendant.