Case Summary (G.R. No. L-39115)
Key Dates and Procedural History
Incident dates: September 26–29, 1999 (drinking sessions and assault).
Information filed: February 10, 2000; petitioner arraigned and pleaded not guilty.
RTC decision: Convicted of homicide (dispositive judgment dated July 2, 2003).
Court of Appeals (CA): Decision affirming RTC conviction dated December 20, 2005; Motion for Reconsideration denied March 13, 2006.
Supreme Court review: Petition under Rule 45 resulted in the challenged CA decision (decision date in the prompt is 2009; the 1987 Constitution is applicable).
Charge and Plea
Petitioner was charged in the Information with the crime of murder (Article 248 of the Revised Penal Code as amended by RA 7659) alleging assault with a bottle, with intent to kill, alleged evident premeditation and treachery. Upon arraignment petitioner pleaded not guilty and proceeded to trial.
Factual Background of the Altercation
Between September 26 and 29, 1999 petitioner and companions engaged in repeated drinking sessions in proximity to the victim’s residence. The victim, Manuel Chy, complained about the noise; petitioner repeatedly made threatening statements in Ilocano expressing intent to harm or “finish” the victim. On September 29 petitioner summoned Chy out of his house, struck him in the face, continued to assault him, and then struck the back of the victim’s head with a beer bottle. Chy fell, tried to flee to his house, phoned his wife and reported difficulty breathing. He was found unconscious and later pronounced dead on arrival at the hospital.
Autopsy and Medical Evidence
The autopsy report listed multiple contusions and a laceration to the lip, showed brain congestion without hemorrhage, significant fatty deposition on the heart’s epicardium, hyperemic changes of the myocardium, coronary arteries with about 30% lumen reduction (described as “gritty”), and histopathology demonstrating mild myocardial fibrosis. Pulmonary edema and hemorrhages were also observed. The autopsy concluded cause of death as myocardial infarction. Medical witnesses (Dr. Cleofas C. Antonio, Dr. Jessica Romero, and Dr. Antonio A. Paguirigan) testified that, given the victim’s preexisting cardiac pathology (fibrosis and arteriosclerosis), an emotional or physiological crisis induced by the beating could precipitate coronary occlusion and myocardial infarction and thus cause death.
Trial Court Findings and Penalty
The Regional Trial Court, Branch 9, Aparri, found petitioner guilty beyond reasonable doubt of homicide (Article 249, Revised Penal Code) and, applying the Indeterminate Sentence Law, imposed an indeterminate penalty with a minimum of ten years prision mayor and a maximum of fourteen years and eight months reclusion temporal. The trial court ordered civil indemnity of P50,000; funeral and burial expenses of P200,000; moral damages of P300,000; loss of earning capacity of P332,000; and costs.
Issues Raised on Appeal and in the Petition
Petitioner advanced several grounds in his appeal: (1) he was not the person who inflicted the injuries (imputing responsibility to others); (2) the cause of death was myocardial infarction (a non‑violent internal cause) and therefore not attributable to his acts; (3) the appellate and trial courts erred in concluding the heart failure resulted from “fright or shock caused by the maltreatment”; and (4) the courts erred in denying acquittal on reasonable doubt.
Standard of Review on Factual Findings and Credibility
The Supreme Court reiterated the narrow scope of factual re‑examination under Rule 45: courts will not disturb trial court factual findings except when unsupported by the record or founded on misapprehension of facts. Petitioner also complained that the judge who wrote the RTC decision did not preside throughout the trial. The Court held that petitioner’s own successful motion for recusal produced this situation and he therefore cannot claim prejudice from that procedural consequence. A successor judge properly may decide a case on the basis of records, transcripts and his own observation of witnesses he heard; such practice does not violate due process.
Credibility Determinations and Evidence Acceptance
The appellate and trial courts assessed witness testimony, including eyewitness accounts from participants who placed petitioner at the scene and described his physical assaults on the victim. Petitioner’s denial and shifting blame were weighed against consistent testimony of the prosecution witnesses and medical evidence. The Court found no basis to overturn these credibility determinations.
Causation Analysis—Linking the Beating to Death
Although the immediate cause of death was myocardial infarction, medical testimony supported a causal link between the beating (and the attendant emotional and physiological strain) and the infarction. Experts explained that the victim’s preexisting myocardial fibrosis and coronary atherosclerosis rendered him susceptible to coronary occlusion triggered by sudden emotion or physical stress. The Court accepted the medical opinion that the emotional crisis and physiological reaction provoked by the assault could have precipitated the fatal myocardial infarction.
Applicable Legal Doctrine on Pre‑Existing Conditions and Causation
The Court applied Article 4(1) of the Revised Penal Code (criminal liability for any person committing a felony although the wrongful act done be different from that which he intended) and cited jurisprudence holding that an attacker remains criminally responsible when death results as a direct consequence of his illegal violence even if the victim had a preexisting condition which contributed to death (e.g., United States v. Brobst; United States v. Rodriguez; Philippine precedents). The maxim “el que es causa de la causa es causa del mal causado” (he who is the cause of the cause is the cause of the evil caused) was invoked to attribute responsibility for the fatal consequence.
Intent, Mitigation and Degree of Offense
Because petitioner did not intend so grave a wrong (i.e., he did not intend to kill), the Court treated that absence of intent as a mitigating circumstance under Article 13(3) of the Revised Penal Code. The unlawful assault was nonetheless a felony; the subsequent death was a natural and direct consequence of that felony, thereby supporting conviction for a grave offense (homicide) though mitigation
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Procedural History
- Petition for review on certiorari under Rule 45 from the Decision dated December 20, 2005 of the Court of Appeals in CA-G.R.-CR No. 27544, which affirmed the July 2, 2003 Decision of the Regional Trial Court (RTC), Branch 9, Aparri, Cagayan, finding petitioner guilty beyond reasonable doubt of homicide.
- The Court of Appeals Decision (Dec. 20, 2005) was penned by Associate Justice Vicente Q. Roxas, with Associate Justices Conrado M. Vasquez, Jr. and Juan Q. Enriquez, Jr. concurring.
- Petitioner’s Motion for Reconsideration before the Court of Appeals was denied by Resolution dated March 13, 2006.
- The Supreme Court rendered its decision in G.R. No. 171951, dated August 28, 2009, authored by Justice Quisumbing.
- The appeal raises predominantly factual questions; petitioner invoked also an argument regarding the judge who penned the RTC decision not being the judge who heard the prosecution evidence.
Charge / Information
- On February 10, 2000, petitioner was charged by Information with murder, alleging an offense “on or about September 29, 1999, in the municipality of Aparri, province of Cagayan,” that he was “armed with a bottle, with intent to kill, with evident premeditation and with treachery,” and that he “assault[ed], attack[ed], box[ed], club[ed] and maul[ed] one Manuel K. Chy, inflicting upon the latter fatal injuries which caused his death,” charged under Article [248] of the Revised Penal Code, as amended by Republic Act No. 7659.
- Upon arraignment, petitioner pleaded not guilty and trial on the merits ensued.
Factual Narrative (as found in the records)
- On or about September 26, 1999, at approximately 11:00 a.m., petitioner, Fidel Foz, Jr., and Armando Foz had a drinking spree at the apartment unit of Bogie Tacuboy, adjacent to Manuel K. Chy’s house.
- At around 7:00 p.m. that day, Chy requested they quiet down because of loud singing from a videoke machine; petitioner was heard to remark in Ilocano: “Dayta a Manny napangas makaala caniac dayta.” (This Manny is arrogant, I will lay a hand on him.)
- On September 28, 1999, the group met again to celebrate a marriage; Maya Mabbun advised them to stop singing; petitioner reacted angrily and said, “Talaga a napangas ni Manny saan ko a pagbayagen daytoy,” meaning “This Manny is really arrogant, I will not let him live long.”
- On September 29, 1999, at around 12:00 p.m., the group again convened at the house of Foz and Garcia; petitioner stated, “Talaga a napangas dayta a day[t]oy a Manny ikabbut ko ita.” (This Manny is really arrogant, I will finish him off today.)
- Later that afternoon the group went drinking, passed by Aurelia Esquibel’s store (Chy’s sister), and petitioner ordered Esquibel to call Chy; Chy came out of his house and approached petitioner.
- Petitioner suddenly punched Chy in the face; Chy cried out in Tagalog, “Bakit mo ako sinuntok hindi ka naman [inaano]?” (Why did you box me[?] I’m not doing anything to you.)
- Petitioner continued to assault Chy; Foz attempted to intervene but was hit on the nose; petitioner grabbed a bottle and struck the lower back portion of Chy’s head; Foz shoved Chy causing him to fall.
- Chy escaped, ran to his house, phoned his wife Josefina to call the police, and complained of difficulty breathing; policemen knocked five times with no answer; Josefina unlocked the door minutes later and found Chy unconscious on the kitchen floor, salivating.
- Chy was pronounced dead on arrival at the hospital; autopsy reported cause of death as myocardial infarction.
Trial Proceedings and Case Management Facts
- The RTC, Branch 9, Aparri, Cagayan, conducted trial; the decision convicting petitioner of homicide was penned by Presiding Judge Andres Q. Cipriano and dated July 2, 2003.
- Judge Conrado F. Manauis had previously presided but inhibited from the proceedings on motion of the petitioner; Judge Cipriano assumed the case, heard defense evidence, recalled Dr. Cleofas C. Antonio for clarification, and presided during the taking of rebuttal testimonies (e.g., Fidel Foz, Jr. and Alvin Pascua).
- Petitioner initially denied employing violence but later, in an undated Memorandum, admitted inflicting injuries and limited his liability to slight physical injuries.
- The Office of the Solicitor General defended the trial court’s assessment of witnesses and maintained that the beating was the proximate cause of death.
Autopsy Report — Physical and Pathological Findings
- Postmortem findings (body embalmed): cyanotic lips and nailbeds.
- Contusions (dark bluish red) at multiple sites with measured sizes: 4.5 x 3.0 cm (lower portion of left ear); 4.0 x 2.8 cm (left inferior mastoid region); 2.5 x 1.1 cm (upper lip); 2.7 x 1.0 cm (lower lip); 5.8 x 5.5 cm (dorsum of left hand).
- Lacerated wound, 0.8 cm, involving mucosal surface of the upper lip on the right side.
- No fractures noted.
- Brain: tortuous vessels; cut sections show congestion; no hemorrhage noted.
- Heart: abundant fat adherent on epicardial surface; cut sections show reddish brown myocardium with area of hyperemia on whole posterior wall, lower portion of anterior wall, and inferior portion of septum; coronary arteries described as “gritty,” with lumen caliber reduced by approximately 30%; histopathology shows mild fibrosis of the myocardium.
- Lungs: pleural surfaces shiny; cut sections show gray periphery with reddish brown central portion and fluid oozing on pressure; histopathology shows pulmonary edema and hemorrhages.
- Kidneys: purplish with glistening capsule; cut sections show congestion; histopathology shows mild lymphocytic infiltration.
- Stomach: one-half full with brownish and whitish materials and partially digested food particles.
- Cause of death certified on the autopsy report: Myocardial Infarction.
Medical Testimony and Interpretation of Cause of Death
- Dr. Cleofas C. Antonio testified that hyperemic changes in the heart muscle observed at autopsy gave a “strong conclusion” of myocardial infarction, and that the most likely cause is occlusion of the blood vessels (coronary occlusion).
- The Sloane medical-legal dictionary definitions were cited/explained in the record: coronary occlusion is the complete obstruction of a heart artery, usually from prog