G.R. No. 172896 - Seguritan y Jara vs. People

Roao Seguritan y Jara, the petitioner, was charged and subsequently convicted for the crime of homicide.
The criminal case originated with an Information charging petitioner with homicide for allegedly punching his relative, Lucrecio Seguritan, which resulted in fatal head injuries.
The incident took place on November 25, 1995, in the municipality of Gonzaga, province of Cagayan.

Prior to the incident, petitioner was engaged in a drinking session with family members at the residence of Manuel dela Cruz in Barangay Paradise, Gonzaga, Cagayan.
An altercation arose when Lucrecio’s carabao allegedly destroyed petitioner’s crops, sparking a heated argument.
During the dispute, petitioner punched Lucrecio twice—even though Lucrecio was seated at the opposite end of a bench—which caused him to lose balance, fall, and hit his head on a hollow block used as an improvised stove.
After the blows, Lucrecio initially lost consciousness and was revived briefly with the assistance of Baltazar Panis, one of the uncles present, before eventually deteriorating.
Lucrecio’s condition worsened as his complexion darkened and a foamy substance began emerging from his mouth around 9 o’clock in the evening, leading to his death on the same night.

Following Lucrecio’s death, his wife, upon learning of petitioner’s involvement, sought the assistance of the National Bureau of Investigation (NBI).
Dr. Antonio Vertido, the NBI Medico-Legal Officer, performed an autopsy which revealed:

Eyewitness testimony, notably by Melchor Panis, corroborated the sequence of events where petitioner delivered two significant punches, which contributed to Lucrecio’s fall and subsequent fatal injuries.
The defense, by contrast, contended that Lucrecio’s death was due to a heart attack and not a direct consequence of petitioner’s actions, supporting this with testimony from Joel Cabebe and Dr. Corazon Flor regarding the Certificate of Death.

In the Regional Trial Court (RTC) decision dated February 5, 2001, petitioner was found guilty beyond reasonable doubt of homicide and sentenced to an indeterminate penalty ranging from 6 years and 1 day of prision mayor to 17 years and 4 months of reclusion temporal.
The RTC also ordered petitioner to pay civil indemnity and damages (including actual, loss of earning capacity, and moral damages) to the heirs of the victim.
On appeal, the Court of Appeals (CA) modified the sentence by reducing the maximum penalty to 12 years and 1 day of reclusion temporal and reaffirmed the ordering of monetary awards with slight modifications:

Actual damages were reclassified and replaced with temperate damages due to the absence of documentary evidence.
Additional amounts for moral damages and loss of earning capacity were also sustained.

A Motion for Reconsideration filed by petitioner was denied by the CA in its Resolution dated May 23, 2006.

Whether the Court of Appeals erred in affirming the trial court’s judgment of conviction against petitioner.

This issue revolves around the appellate review of factual findings made by the trial court, which are generally given significant deference on appeal.

Whether the appellate court erred in convicting the accused of homicide given the arguments presented by petitioner regarding the causation of Lucrecio’s injuries and the alternative theory of death by heart attack.

The dispute includes whether the evidence supports a finding of homicide as opposed to a charge of reckless imprudence resulting in homicide.