Facts:

The case involves Domingo Ural, a policeman accused of murdering Felix Napola. The incident occurred on July 31, 1966, in the municipal jail of Buug, Zamboanga del Sur. The prosecution's key witness, Brigido Alberio, testified that he witnessed Ural physically assault Napola, who was a detention prisoner. Alberio recounted that Ural boxed Napola, causing him to collapse, and then stepped on him. Ural subsequently returned with a bottle, poured its contents on Napola, and ignited it, resulting in severe burns. Napola screamed for help, but no one came to his aid. Alberio left the scene, disturbed by the brutality he had witnessed.

Dr. Luzonia R. Bakil, the municipal health officer, treated Napola for second-degree burns and testified that without proper medical intervention, the injuries could lead to death. Napola succumbed to his injuries on August 25, 1966, with the cause of death listed as "burn." The trial court noted the prosecution's failure to pres...

Facts:

1. Background of the Incident:

   • Domingo Ural, a policeman, was accused of murdering Felix Napola, a detention prisoner, on July 31, 1966, in Buug, Zamboanga del Sur.
   • The incident occurred in the municipal jail where Ural was on guard duty.

2. Eyewitness Testimony:

   • Brigido Alberio, a former detention prisoner, testified that he witnessed Ural physically assault Napola, pour a flammable substance on him, and set him on fire.
   • Alberio heard Napola scream for help, but no one came to his aid. Ural later warned Alberio to keep quiet about the incident.

3. Medical Evidence:

   • Dr. Luzonia R. Bakil, the municipal health officer, treated Napola and confirmed he sustained second-degree burns on multiple parts of his body.
   • She testified that without proper medical treatment, the burns would lead to death due to complications like toxemia and tetanus.
   • Napola died on August 25, 1966, with "burn" listed as the cause of death on the death certificate.

4. Defense’s Version:

   • Ural claimed he heard Napola scream for help and found his shirt on fire. He denied setting Napola on fire and stated he helped remove the burning shirt.
   • Other witnesses, including Felicisima Escareal and Teofilo Matugas, supported Ural’s claim that he assisted Napola.

5. Prosecution’s Shortcomings:

   • The trial court criticized the prosecution for failing to present key witnesses, such as Juanito de la Serna and Ernesto Ogoc, who had executed a joint affidavit implicating Ural.
   • Rufina Paler, Napola’s widow, was also not presented as a witness, despite her potential to provide a dying declaration or res gestae testimony.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Causal Relationship Between Act and Death:

   • Under Article 4 of the Revised Penal Code, criminal liability is incurred even if the wrongful act differs from what was intended. The Court applied the doctrine that "he who is the cause of the cause is the cause of the evil caused."
   • Ural’s act of setting Napola on fire directly caused his death, regardless of whether Ural intended to kill him.

2. Abuse of Public Position:

   • Ural’s position as a policeman enabled him to commit the crime, as he had access to the jail and control over the detainees. This constituted an aggravating circumstance under Article 14 of the Revised Penal Code.

3. Mitigating Circumstance:

   • The Court recognized that Ural had no intent to kill Napola, which mitigated the crime. However, this did not absolve him of liability for the resulting death.

4. Penalty Imposed:

   • The Court upheld the penalty of reclusion perpetua, the medium period of the penalty for murder, as it balanced the aggravating and mitigating circumstances.