Case Digest (G.R. No. 199892)
Facts:
On the evening of August 10, 2002, in Barangay West Dirita, San Antonio, Zambales, Arturo Punzalan, Jr., while driving a maroon Nissan van (plate DRW 706) and under the influence of alcohol, became involved in an altercation at the “Aquarius” videoke bar with six Philippine Navy seamen assigned to the Naval Education and Training Command (NETC). After a misunderstanding escalated, the sailors left the bar in three groups and proceeded toward their camp. Near the NETC sentry gate, Private First Class Alejandro Dimaala and Seaman First Class Noel de Guzman flagged down Punzalan’s speeding van. Without warning, Punzalan accelerated, swerved to the right, and deliberately ran over the sailors walking along the roadside. Two victims—SN1 Arnulfo Andal and SN1 Antonio Duclayna—died of massive blunt trauma; three others sustained serious injuries; one narrowly escaped harm. Police responding to the scene arrested a visibly intoxicated Punzalan at his home, seizing his damaged van. A regCase Digest (G.R. No. 199892)
Facts:
- Procedural History
- The Regional Trial Court (RTC) of Iba, Zambales convicted Arturo Punzalan, Jr. of the complex crime of double murder with multiple attempted murder, sentencing him to reclusion perpetua and ordering payment of civil, moral, exemplary, and temperate damages, plus loss of earning capacity.
- On appeal, the Court of Appeals (CA) denied relief, modified the amounts of damages, and affirmed the conviction. Appellant elevated the case to the Supreme Court.
- Incident on August 10, 2002 at NETC, San Antonio, Zambales
- Six enlisted Philippine Navy personnel (SN1 Andal, Duclayna, Bacosa, Domingo, Cuya, Bundang) drank at the “All-in-One” canteen, then at the “Aquarius” videoke bar, where appellant Sampal encountered SN1 Bacosa over a flickering light and was provoked.
- The navy men left in three groups; appellant, drunk, flagged down his Nissan van at the sentry gate, threatened them, then accelerated and swerved to the right, running over and killing Andal and Duclayna, injuring three others, while one narrowly escaped.
- Investigation and Forensic Findings
- Sentries reported the incident; police arrested appellant at home, seized the van with a damaged bumper; appellant admitted being drunk.
- Post-mortem by Dr. Cordero: Andal and Duclayna died of massive blunt traumatic injuries to head, thorax, abdomen, and liver. Cuya, Bacosa, Bundang sustained non-fatal lacerations and abrasions.
- Pleadings and Trial
- Information charged appellant with double murder of Andal and Duclayna, frustrated murder of Cuya, Bacosa, Bundang, and attempted murder of Domingo, attending circumstances: treachery, evident premeditation, cruelty, and use of motor vehicle.
- Appellant invoked justification of avoidance of greater evil, alleging attack by navy personnel; two defense witnesses testified but failed to corroborate his version.
- RTC and CA found prosecution witnesses credible, defense unsubstantiated, treachery and use of vehicle proven, and denied appellant’s defense.
Issues:
- Factual Issues
- Did appellant actually face imminent danger justifying avoidance of greater evil?
- Was treachery present and properly alleged in the Information?
- Legal Issues
- Does appellant’s single act of accelerating and swerving constitute a complex crime of double murder with multiple attempted murder under Article 48 of the Revised Penal Code (RPC)?
- What penalties and aggravating or qualifying circumstances apply (Articles 11, 48, 248, 250, 63 RPC; RA 9346)?
- Are the awarded civil, moral, exemplary, temperate damages and loss of earning capacity appropriate?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)