G.R. No. 164815 - Valeroso vs. Court of Appeals

On the night of April 3, 1934, during a dance held in a private house in the barrio of Maya, municipality of Abuyog, Province of Leyte, the appellant, Inogentes Moldes, engaged in disruptive behavior at the event.
The deceased, acting as the master of ceremonies, reproved the appellant for dancing out of turn, which escalated the situation.

Following the reproach, the appellant moved to the porch and began cutting down the dance decorations with his bolo, exhibiting aggressive conduct.
He then advanced to the yard, challenging bystanders to a fight, and proceeded to chop at the bamboo trees while repeatedly issuing a challenge to engage in combat.
The deceased, though unarmed and attempting a conciliatory approach, descended the stairs and engaged the appellant in a friendly manner.
As the deceased nearly reached the ground, the appellant struck him with his bolo, inflicting a severe wound.

The injury was located on the lower portion of the left arm, extending downward as far as the antecubital fossa, and involved significant damage by cutting through the inferior part of the biceps muscle and branches of the brachial artery.
The wound measured approximately 3 inches in length, 2.5 inches in width, and 1.5 inches in depth, as described by the sanitary inspector during the post mortem examination.
After inflicting the wound, the appellant also caused a slight wound on the deceased’s back before fleeing the scene.

The assault wound was observed by a sanitary inspector the following morning, and initial treatment was administered.
The deceased, however, was kept under the care of a local “curandero” due to the absence of proper modern surgical treatment facilities in the outlying barrio.
The insufficient treatment failed to control the hemorrhage, ultimately leading to the deceased’s death on April 15, 1934.

The defense contended that the appellant’s disruptive behavior was in the context of the dance, alleging that the deceased acted as the aggressor by first striking him with a cane.
It was further argued that as the appellant attempted to retreat, the deceased pursued him for about 200 yards, and the ensuing self-defense led to the appellant ultimately using his bolo to wrest away the deceased’s weapon.
The defense also suggested that the fatal outcome was due in part to the lack of proper surgical treatment available in the barrio rather than solely the result of the appellant’s actions.
Notably, the trial court found the testimony of the defense witnesses less clear and convincing compared to that of the prosecution, and it did not accept the self-defense claim.

Whether the appellant’s actions, particularly the deliberate and forceful use of a lethal weapon, established criminal liability for homicide.
The extent to which the appellant should be held responsible for the natural and foreseeable consequences of his conduct.

Whether the defense’s contention that the deceased was the aggressor, and that the appellant’s actions were in self-defense, was supported by clear and convincing evidence.
Whether the evidence presented at trial adequately justified a determination of self-defense under the circumstances.

Whether the failure to secure proper modern surgical treatment, in an area where such services were not readily available, could mitigate the appellant’s criminal responsibility for the death of the deceased.
The legal principle regarding the responsibility for the natural consequences of a violent act, irrespective of subsequent medical errors or negligence.

Whether the probing questions regarding the character and habits of the deceased were pertinent to establishing the issues of self-defense and aggressor status.
If such lines of inquiry, even if potentially prejudicial, affected the fairness of the trial.