Case Digest (G.R. No. 150917)
Facts:
Artemio Yadao v. People of the Philippines, G.R. No. 150917, September 27, 2006, First Division, Chico-Nazario, J., writing for the Court.Petitioner Artemio Yadao was charged by information dated 21 April 1989 with homicide under Article 249 of the Revised Penal Code for the death of Deogracias Gundran; the case was docketed as RTC, Bauang, La Union, Criminal Case No. 1042-BG. Yadao pleaded not guilty and went to trial. The prosecution presented four witnesses (Carmelita Limon, Teofilo Gundran, Napoleon Estigoy and Dr. Arturo Llavore). The defense presented five witnesses including petitioner himself and Dr. Magdalena Alambra and introduced Dr. Alambra’s autopsy report.
The basic factual narrative was undisputed that on 1 October 1988, during petitioner’s birthday gathering, Yadao slapped the intoxicated victim who fell and struck his head on the edge of a table; the victim left the house and two days later (3 October 1988) died while having difficulty breathing. The first autopsy, performed the day of death by Dr. Alambra, found a large scalp hematoma and advanced pulmonary tuberculosis and concluded cause of death as cardio-respiratory arrest due to pulmonary tuberculosis. The victim’s father arranged a re-autopsy by the NBI; on 11 October 1988 Dr. Arturo Llavore’s report found extensive scalp hematoma, marked cerebral congestion and opined cause of death as “cerebral edema, severe, secondary to traumatic injuries; head.”
On 28 March 1996 the RTC (Presiding Judge Fortunato V. Panganiban) convicted Yadao of homicide, relying primarily on Dr. Llavore’s findings and imposing an indeterminate sentence (prision correccional to prision mayor) and ordering P50,000 indemnity to the heirs. Yadao appealed to the Court of Appeals which, in a Decision dated 18 April 2001, affirmed the RTC “in toto.” A motion for reconsideration was denied by CA Resolution of 13 November 2001. Petitioner filed a petition for review on ce...(Pro-only)
Issues:
- Was the guilt of petitioner proven beyond reasonable doubt—specifically, did the prosecution establish the corpus delicti and the proximate causal link between the head injury and death?
- May civil indemnity be awarded to the heirs despite the accused’s acquittal on t...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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