G.R. No. 160341 - Senoja vs. People

The case arose from a petition for review under Rule 45 challenging the decision of the Court of Appeals (CA) which in turn had affirmed, with modification, the Regional Trial Court (RTC) decision.
The RTC, Branch 39 in Lingayen, Pangasinan, found petitioner Rodel Urbano guilty beyond reasonable doubt of homicide under Article 249 of the Revised Penal Code (RPC).

On or about September 28, 1993, around 8:00 p.m., petitioner and victim Brigido Tomelden were present at the compound of the Lingayen Water District (LIWAD) after a picnic in Bugallon, Pangasinan.
A heated altercation ensued inside the compound following insulting remarks exchanged between the two, with Tomelden hurling insults at petitioner.
The confrontation escalated into a fist fight wherein petitioner delivered a “lucky punch” on Tomelden’s face, which rendered the victim unconscious.
Eyewitness, Orje Salazar, testified that despite attempts to break up the fight, the confrontation continued until the decisive punch was landed.

Following the incident, petitioner and his co-workers took the injured Tomelden to the LIWAD office and subsequently to a nearby hospital for treatment.
Tomelden complained of severe head pain, dizziness, headache, and other symptoms; he was admitted and treated on multiple occasions between September 29, 1993, and October 10, 1993.
On October 10, 1993, Tomelden’s condition worsened and he eventually died at 9:00 p.m. The medical findings, including an autopsy report, indicated “cardio-respiratory arrest secondary to cerebral concussion with resultant cerebral hemorrhage due to mauling incident” as the cause of death.

At trial, the prosecution presented evidence based on eyewitness testimony (notably from Salazar), as well as detailed medical reports by Dr. Daisy Arellano which linked the injuries sustained from the punch to Tomelden’s subsequent death.
The victim’s wife, Rosario, testified regarding the victim’s complaints and worsening condition after the initial assault.
The defense argued that petitioner had no intent to kill and attributed the death to pre-existing conditions such as malignant hypertension, contending that the punch did not constitute the proximate cause of death.

The RTC sentenced petitioner to an indeterminate prison term of eight (8) years and one (1) day (as minimum) to seventeen (17) years and four (4) months, along with the payment of PHP50,000.00 in indemnity to the heirs of Tomelden.
On appeal, the CA, while upholding the conviction, modified the sentence and awarded moral damages, noting that the “lucky punch” was the proximate cause of death, and affirmed the trial court’s findings after considering the mitigating circumstances presented.

Whether the “lucky punch” delivered by petitioner, occurring 12 days before the victim’s death, was the proximate cause of death.
Whether the intervening period during which Tomelden continued to work and sought medical attention affects the causal link between the punch and his eventual death.

Whether the eyewitness testimony and medical evidence were sufficient to establish beyond moral certainty that the punch was the direct cause of Tomelden’s death.
Whether the factual findings of the RTC regarding the sequence of events and the credibility of the witnesses should be given deference.

Whether the mitigating circumstances of sufficient provocation (immediately preceding the act) and lack of intent to commit a grave wrong are applicable and sufficiently proven.
Whether these mitigating circumstances warrant a reduction in the severity of the penalty imposed on petitioner.