Title
People vs. Orlito Villacorta
Case
G.R. No. 186412
Decision Date
Sep 7, 2011
Orlito Villacorta was convicted of murder for stabbing Danilo Cruz, but the Supreme Court reversed the decision, finding him guilty of slight physical injuries instead, citing a lack of intent to kill and intervening causes for Cruz's death.

Case Digest (G.R. No. 186412)
Expanded Legal Reasoning Model

Facts:

  • Parties and Case Background
    • Orlito Villacorta (Accused-Appellant) was charged with murder for stabbing Danilo Salvador Cruz (Victim) leading to the latter's death.
    • The incident allegedly occurred on January 23, 2002, in Navotas, Metro Manila.
    • The Information stated that Villacorta, armed with a sharpened bamboo stick, stabbed Cruz with intent to kill, with treachery and premeditation.
    • Villacorta pleaded not guilty when arraigned on September 9, 2002.
  • Prosecution Evidence
    • Cristina Mendeja, a witness and regular store owner, testified that Villacorta stabbed Cruz at around 2:00 AM while Cruz was buying bread at her store.
    • The bamboo stick broke and was left embedded in Cruz’s body; Villacorta fled immediately after stabbing.
    • Mendeja and neighbor Aron brought Cruz to Tondo Medical Center for treatment.
    • Dr. Domingo Belandres, via medical records, testified that Cruz died of tetanus infection secondary to the stab wound at San Lazaro Hospital on February 15, 2002.
    • Prosecution and defense agreed to dispense with the testimony of Dr. Deverni Matias who attended to Cruz at San Lazaro Hospital.
  • Defense Evidence
    • Villacorta denied stabbing Cruz and recounted an altercation where he boxed Cruz after Cruz put his arm on his shoulder.
    • Villacorta claimed he was unaware Cruz was hurt and only learned of Cruz’s death after his arrest on July 31, 2002.
  • Lower Courts’ Decisions
    • RTC, Branch 170, Malabon, found Villacorta guilty of murder with treachery and sentenced him to reclusion perpetua, with civil indemnity to Cruz’s heirs.
    • The Court of Appeals affirmed the RTC decision.
  • Appellate Proceedings
    • Villacorta filed Notice of Appeal and Appellant’s Brief; the People, through the OSG, filed Appellee’s Brief.
    • Both parties manifested no supplemental briefs.

Issues:

  • Whether or not the prosecution proved Villacorta’s guilt beyond reasonable doubt for murder.
  • Whether treachery was properly appreciated as a qualifying circumstance.
  • Whether Villacorta should be held liable for murder or a lesser offense such as slight physical injuries.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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