Case Digest (G.R. No. 280)
Facts:
The case, United States vs. Eleuterio Marasigan, arose from an incident on the evening of September 17, 1892, in Calaca, Batangas. Engracio Ronimo, a lieutenant, was alerted to a quarrel between Eleuterio Marasigan and Severo Magsino regarding the alleged theft of a bull belonging to Magsino. Upon investigating, Lieutenant Ronimo attempted to take the parties to the municipal building for resolution. Justice of the Peace Arcadio de Joya arrived and learned about the dispute, prompting him to order everyone downstairs. During a discussion, Marasigan seized the weapon of the justice and shot Lieutenant Ronimo in the head, leading to his immediate injury. Witnesses at the scene corroborated these events. Following the injury, Ronimo received assistance from local curanderos. He claimed that his recovery took a month and two days, including twenty days of incapacity, and incurred expenses of 12 pesos. However, witnesses, including the curanderos, had conflicting statements regardingCase Digest (G.R. No. 280)
Facts:
- Incident Overview
- Date and Time:
- The incident occurred about 7 o’clock on the evening of September 17, 1892.
- Location:
- In front of the house of Geronimo Ramos in the town of Calaca, Batangas.
- Principal Persons Involved:
- Engracio Ronimo: A lieutenant of Calaca, Batangas.
- Eleuterio Marasigan: Accused of discharging a firearm.
- Severo Magsino: Accuser in a quarrel, alleging theft of his bull.
- Arcadio de Joya: The justice of the peace who intervened in the altercation.
- Sequence of Events Leading to the Incident
- Observation of Disturbance:
- Lieutenant Ronimo, while stationed outside, observed a quarrel taking place upstairs at Geronimo Ramos’s residence.
- Initial Investigation:
- Ronimo went upstairs to investigate and discovered a quarrel between Marasigan and Magsino.
- Magsino accused Marasigan of having stolen a bull.
- Attempted Intervention:
- Lieutenant Ronimo attempted to detain the parties and escort them to the municipal building for proper resolution.
- Involvement of Law Enforcement and Judicial Authority
- Arrival of the Justice of the Peace:
- Arcadio de Joya appeared at the scene and demanded that everyone gather downstairs.
- Private Arrangement for Settlement:
- A conversation in Spanish took place between Marasigan and de Joya as they arranged to settle the matter privately.
- Objection and Escalation:
- Despite the ongoing discussion, Lieutenant Ronimo objected to the private arrangement, prompting further developments.
- the Shooting Incident
- Act of Violence:
- In response to the objection, Marasigan seized the gun carried by the justice of the peace and discharged a shot.
- Injury Sustained:
- The shot struck Lieutenant Ronimo in the head, causing him to fall immediately.
- Witness Testimonies:
- Several witnesses present confirmed that Marasigan was the one who fired the gun at Ronimo.
- Medical Examination and Discrepancies in Recovery Accounts
- Treatment by Curanderos:
- Two curanderos administered first aid to the wounded lieutenant.
- Conflicting accounts of the healing period emerged:
- The injured party stated that his recovery took one month and two days, with an inability to work for the first twenty days.
- One curandero claimed a cure period of twenty days, while the other maintained it took only ten days.
- Municipal Physician’s Findings:
- The municipal physician identified a scar in the left parietal region.
- Determined that the bullet affected only the scalp without penetrating the skull.
- Predicted complete healing within 20 to 30 days, provided proper treatment and absence of complications.
- Judicial Proceedings and Prior Judicial Actions
- Initial Proceedings and Charges:
- Charges were filed against Eleuterio Marasigan and Arcadio de Joya for the crime of lesiones graves.
- Trial Court Decision (May 2, 1896):
- Marasigan was sentenced for discharging a firearm and causing lesiones menos graves.
- Penalties included:
- Three years and six months of prision correccional.
- Accessory penalties.
- An indemnity payment of 18 pesos to the injured party or subsidiary imprisonment if insolvent.
- Half of the court costs, with the other half being declared de oficio.
- Arcadio de Joya was acquitted.
- Subsequent Developments in the Proceedings:
- Marasigan absconded after the appeal was admitted and was declared in default.
- Proceedings were suspended until his reappearance on November 3, 1902.
- A motion was filed by counsel claiming that Marasigan had been pardoned by the previous government, but the alleged decree of pardon was never produced.
- It was later noted that Arcadio de Joya had since died.
- Evidence and Crime Classification
- Nature of the Crime:
- The facts established that Marasigan’s act of firing the weapon constituted the crime of discharging a firearm causing lesiones menos graves.
- Differentiation from Other Crimes:
- The act was not classified as an armed aggression against an official since Lieutenant Ronimo was not fulfilling any official duties at that time.
- It could not be deemed as frustrated murder or homicide due to insufficient evidence of an intent to kill.
- Corroboration by Witnesses:
- Multiple eyewitness accounts confirmed that Marasigan was the sole individual responsible for firing the shot despite conflicting exculpatory statements by his relatives.
Issues:
- Criminal Liability and Classification of the Offense
- Whether the act committed by Marasigan should be classified solely as the discharge of a firearm causing lesiones menos graves.
- Determination if the shooting could rather be construed as an act of armed aggression, frustrated murder, or homicide based on the circumstances and intent.
- Evidentiary Sufficiency and Witness Testimonies
- The reliability and consistency of witness testimonies versus the exculpatory claims made by relatives of the accused.
- The acceptance, or lack thereof, of mitigating evidence concerning the duration and severity of the injuries as provided by medical witnesses.
- Effect of Alleged Pardon
- Whether the alleged pardon by the former government, though not substantiated with the original decree, might exonerate Marasigan from criminal liability.
- The legal ramifications of failing to produce the requisite pardon document during trial proceedings.
- Appropriate Penalty under the Law
- Whether the imposition of the penalty under Article 89 of the Penal Code (integrating the offense with its accessory penalties) was proper.
- Consideration of whether the absence of mitigating or aggravating circumstances justified application of the penalty at the medium grade of the maximum degree.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)