G.R. No. 208908 - The Coffee Bean and Tea Leaf Philippines, Inc. vs. Arenas

On July 7, 1996, in the Municipality of Sta. Rosa, Laguna, an altercation between Rufino Mallari y Ilag and Joseph Galang culminated in a fatal vehicular incident.
Prior to the incident, Joseph Galang admonished Rufino and his brothers (Ino and Felix Mallari) for speeding near Joseph’s residence. This warning escalated tensions between the parties.
Although Joseph and his brothers later apologized to Rufino to defuse the situation, it appears that Rufino continued to harbor ill feelings.

While driving his truck near Joseph’s house, Rufino was reportedly angered by Joseph’s admonition against speeding.
Rufino, along with his brothers, challenged Joseph to a fight; however, Joseph ignored the challenge and accepted the apology offered by him and his brothers.

Joseph was watching a basketball game with Liza Galang.
Rufino, accompanied by his brothers and allegedly armed with bladed weapons, arrived and attempted to stab Joseph, who managed to run away.
Unable to catch up with the fleeing Joseph, Rufino boarded a nearby parked Isuzu Canter Elf truck and resumed the chase.

Rufino, in deliberate pursuit, used the truck to run over Joseph, resulting in immediate death from crushing head injuries.
Testimonies confirmed that Joseph sustained multiple skull fractures and brain tissue evisceration, as detailed in the medico-legal report.

Liza Galang testified regarding the sequence of events: the initial admonition, the attempt to stab Joseph, and the subsequent truck chase and bumping incident.
Edgar Bawar, a friend of Joseph, corroborated Liza’s account by stating that Rufino, driving the truck, deliberately bumped and killed Joseph.
Dr. Erwin Escal confirmed that the cause of death was a crushing injury on the head secondary to the vehicular accident.

Rufino Mallari y Ilag testified that while driving at approximately eighty kilometers per hour with his wife Myrna on board, he saw Joseph on the road; he claimed that after blowing his horn three times, Joseph allegedly moved to the middle of the road and threw stones, which allegedly struck him and caused him to lose control of the truck.
Myrna Mallari corroborated parts of Rufino’s version by testifying that she observed Joseph throwing stones; however, her testimony was inconsistent, particularly regarding the speed of the truck.
Medical testimonies by Dr. Divina Palarca and further confirmation by Dr. Escal were presented to establish that Rufino was suffering from pulmonary tuberculosis, though no conclusive link was made between his illness and his inability to control the truck.

The prosecution’s witnesses (Liza Galang and Edgar Bawar) provided consistent accounts that were made within twenty-four hours of the incident, lending credibility to their testimonies.
Conversely, Rufino and Myrna’s testimonies were riddled with inconsistencies regarding details such as the speed of the truck, the distance at which Joseph was first seen, and the circumstances of the alleged stone-throwing incident.

The Regional Trial Court, Branch 25 of BiAan, Laguna, convicted Rufino of murder based on the evidence of deliberate action and the use of a motor vehicle as a qualifying circumstance.
Rufino’s Appellant’s Brief raised three main arguments:

The incident did not display criminal intent or malice.
The use of the motor vehicle was merely incidental and should not qualify the crime as murder.
Voluntary surrender should be considered as a mitigating circumstance.

The Office of the Solicitor General (OSG) argued for the affirmance of the conviction but proposed that the death penalty be reduced to reclusion perpetua in light of Rufino’s voluntary surrender.

Whether the trial court correctly found that Rufino Mallari y Ilag deliberately used his truck to bump and kill Joseph Galang, thereby inflicting the fatal injuries.

Assessment of the credibility of conflicting testimonies provided by the prosecution and defense witnesses.

Whether the use of a motor vehicle in the commission of the crime should qualify as an aggravating circumstance, elevating the crime to murder rather than a lesser offense.
Whether the mitigating circumstance of voluntary surrender, as purported by Rufino, should lead to a reduction of the penalty imposed.
Whether the award for damages, particularly the compensatory, moral, exemplary, and indemnity ex delicto, was properly supported by the evidence and in accordance with the legal requirements.