Title
People vs. Ligon y Trias
Case
G.R. No. 74041
Decision Date
Jul 29, 1987
A 17-year-old vendor died after falling from a moving vehicle during a cigarette transaction; the accused was acquitted of criminal charges but held civilly liable for negligence.

Case Digest (G.R. No. 74041)
Expanded Legal Reasoning Model

Facts:

  • Procedural Background
    • The case is an appeal from the decision of the Regional Trial Court of Manila, Branch xx, rendered on February 17, 1986.
    • Fernando Gabat was convicted of Robbery with Homicide and sentenced to reclusion perpetua, while his co-accused, Rogelio Ligon, remains at large.
    • The case involves both criminal and civil liabilities, with the criminal conviction being appealed while the civil liability is also at issue.
  • The Incident
    • Date, Time, and Location
      • The fatal incident occurred on Sunday, October 23, 1983, at about 6:10 p.m.
      • The incident took place along major thoroughfares of Manila, specifically near the intersection of Quezon Boulevard and Lerma Street before reaching the C.M. Recto underpass.
    • Involved Parties and Vehicles
      • Fernando Gabat, the accused-appellant, was a passenger on a 1978 Volkswagon Kombi owned by his father, Antonio Gabat.
      • Rogelio Ligon, the driver of the Kombi and co-accused, was present during the incident.
      • Jose Rosales y Ortiz, a 17-year-old cigarette vendor and working student, was the victim.
      • A taxicab, driven by Prudencio Castillo, followed the Kombi and became an important witness.
      • A jeep, later revealed to be carrying police officers (Patrolmen Leonardo Pugao and Peter Ignacio), joined the chase and assisted in apprehending the occupants of the Kombi.
  • Sequence of Events
    • Pre-Incident Transaction
      • While the Kombi was stopped at a red light, Gabat called to a cigarette vendor (Rosales) to buy cigarettes.
      • A transaction took place where Rosales handed two sticks of cigarettes to Gabat and exchanged a P5.00 bill.
    • The Moment of the Incident
      • As soon as the traffic light turned green, the Kombi accelerated toward Quiapo.
      • During this acceleration, conflicting versions emerged regarding the interaction:
        • The prosecution contended that Gabat forcibly grabbed the cigarette box from Rosales, prying his hand off the windowsill, which caused Rosales to lose his grip and fall.
ii. The defense maintained that the cigarette box was inadvertently dislodged as the Kombi sped off, and that Gabat had attempted to signal the driver to slow down to allow Rosales to get off safely.
  • Aftermath and Apprehension
    • Rosales, after falling from the moving Kombi, was immediately assisted by bystanders and rushed to the Philippine General Hospital, where he later succumbed to injuries on October 30, 1983.
    • Following the incident, the taxicab driver Castillo pursued the Kombi, and with the help of police officers in a jeep, managed to halt the vehicle.
    • Gabat, Ligon, and a third occupant, Rodolfo Primicias, were detained and brought to the Western Police District.
    • Initial investigations led to separate informations: one charging Ligon with Homicide through Reckless Imprudence and a later supplemental charge for Robbery with Homicide filed against both Gabat and Ligon.
  • Evidence and Testimonies
    • Testimony of Prudencio Castillo
      • Castillo, driving a low-slung taxicab that followed the Kombi at a distance of about three meters, testified that he witnessed Gabat forcibly grabbing the cigarette box from Rosales.
      • His account included details such as Gabat’s act of forcibly prying the victim’s hand away from the Kombi’s windowsill and the victim’s subsequent fall.
    • Testimony of Fernando Gabat (Defense Version)
      • Gabat testified that the cigarette vendor had placed the box on the windowsill and that he had signaled the driver to help Rosales disembark once the Kombi slowed down.
      • He contended that the sequenced events leading to the fall were not intentionally caused by him.
    • Documentary Evidence and Supplementary Affidavits
      • The investigation included statements from Castillo and Rodolfo Primicias, along with a Traffic Accident Report prepared by Pfc. Fermin Payuan.
      • A supplementary affidavit, sworn to by Castillo before the Assistant City Fiscal on January 17, 1984, added crucial details used in refiling the information for Robbery with Homicide.
  • Autopsy and Medical Findings
    • An autopsy conducted on October 31, 1983, by Dr. Orlando V. Salvador revealed that the cause of death of Rosales was “pneumonia hypostatic, bilateral, secondary to traumatic injuries of the head.”
    • These findings supported the contention that the injuries sustained by Rosales were a direct consequence of the incident involving the moving Kombi.

Issues:

  • Criminal Liability
    • Whether the evidence presented at trial was sufficient to establish, beyond reasonable doubt, that Fernando Gabat committed Robbery with Homicide.
    • Whether the actions of Gabat—specifically his handling of the cigarette transaction and subsequent failure to stop the vehicle—directly caused Jose Rosales to suffer injuries that led to his death.
  • Evaluation of Witness Testimony and Evidence
    • The reliability of Prudencio Castillo’s testimony given the circumstances under which he observed the incident, including:
      • The positioning of his taxicab relative to the Kombi.
      • Obstructed views due to the design of the 1978 Volkswagon Kombi’s rear windshield.
      • The extremely brief duration of the key moment when the incident occurred.
    • The credibility of the conflicting versions provided by the prosecution and the defense.
  • Civil Liability
    • Whether Fernando Gabat’s actions, even if not criminally proven beyond reasonable doubt, rendered him civilly liable for the damages arising from Rosales’ death.
    • The appropriate standard of proof (preponderance of evidence) applicable in determining civil liability versus the criminal standard (beyond reasonable doubt).
  • Legal Distinction Between Criminal and Civil Liability
    • The implication of Article 29 of the Civil Code regarding the separate nature of criminal acquittal and civil liability.
    • Whether an acquittal in a criminal case automatically precludes the imposition of civil damages.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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