Case Summary (G.R. No. 171951)
Key Dates
• September 26, 1999: First drinking session and quarrel.
• September 28, 1999: Renewed confrontation at a marriage celebration.
• September 29, 1999: Fatal mauling and subsequent death of Chy.
• February 10, 2000: Filing of Information charging murder.
• July 2, 2003: RTC decision convicting Garcia of homicide.
• December 20, 2005: CA Decision affirming RTC.
• March 13, 2006: CA Resolution denying reconsideration.
• August 28, 2009: Supreme Court decision.
Applicable Law
• Revised Penal Code, Article 248 (murder) as amended by R.A. 7659.
• Revised Penal Code, Article 249 (homicide) and Article 13(3) (mitigating circumstance).
• Revised Penal Code, Article 4(1) (liability for unintended consequences).
• Indeterminate Sentence Law (Act No. 4103 as amended).
• 1987 Philippine Constitution.
Factual Antecedents
During three drinking sessions on September 26 and 28 and September 29, 1999, Garcia and companions used a videoke, disturbing Chy. Verbal threats in Ilocano indicated Garcia’s intent to harm Chy. On the afternoon of September 29, the group gathered at Foz’s residence, then proceeded to drink at two stores. There, Garcia summoned Chy, punched him, and struck him with a beer bottle. Chy fled home, complained of breathing difficulty, and shortly thereafter was found unconscious and pronounced dead at the hospital. Autopsy attributed death to myocardial infarction.
Trial Court Decision
The RTC (Branch 9, Aparri) found Garcia guilty beyond reasonable doubt of homicide (Article 249, RPC), applying the Indeterminate Sentence Law. He was sentenced to an indeterminate term of 10 years of prisión mayor (minimum) to 14 years and 8 months of reclusion temporal (maximum). He was ordered to pay civil indemnity (₱50,000), funeral and burial expenses (₱200,000), moral damages (₱300,000), and loss of earning capacity (₱332,000).
Court of Appeals Decision
The CA denied Garcia’s appeal and affirmed the RTC decision in toto on December 20, 2005. A subsequent motion for reconsideration was denied on March 13, 2006.
Issues on Review
- Whether Garcia inflicted the injuries on Chy.
- Whether Chy’s death by myocardial infarction, a nonviolent cause, absolves Garcia.
- Whether Chy’s heart failure was due to “fright or shock” from maltreatment.
- Whether reasonable doubt mandates acquittal.
Supreme Court’s Jurisdiction and Standard of Review
The petition was brought under Rule 45 (certiorari). Factual findings of trial courts are binding unless unsupported by evidence or based on misapprehension of facts. Neither exception is present.
Credibility and Validity of Proceedings
Allegation that the ponente judge did not hear all testimony fails, as petitioner himself sought the prior judge’s inhibition. The succeeding judge reviewed stenographic notes, heard defense evidence, and legally rendered a valid decision without violating due process.
Causal Connection and Medical Evidence
Autopsy documented contusions and lacerations; myocardial infarction was immediate cause of death. Expert testimony established that Chy had coronary arteriosclerosis and mild myocardial fibrosis from a prior heart attack. The beating induced emotional stress triggering coronary occlusion. Both Dr. Antonio and Dr. Paguirigan confirmed that while the physical blows were not directly lethal, the emotional crisis precipitated Chy’s fatal heart attack.
Legal Doctrine on Unintended Consequences
Under Article 4(1), a felon is liable for all natural and logical results of his unlawful act. Jurisprudence (e.g., United States v. Brobst; U.S. v. Rodriguez) holds that an aggressor remains criminally responsible for a death hastened by a preexisting condition. Garcia’s intent to harm and the ensuing beating satisfy the elements for homicide.
Mitigating Circumstances and Penalty
Garcia lacked intent to cause death, a mitigating circumstance under Article 13(3), and no agg
Case Syllabus (G.R. No. 171951)
Procedural History
- Petitioner Amado Garcia was charged with murder before the RTC of Aparri, Cagayan (Branch 9) on February 10, 2000.
- RTC, Branch 9 rendered judgment on July 2, 2003, finding petitioner guilty beyond reasonable doubt of homicide under Article 249 of the Revised Penal Code and sentencing him to an indeterminate term of ten years of prisión mayor (minimum) to fourteen years and eight months of reclusión temporal (maximum), plus civil liability.
- On appeal, the Court of Appeals, in a Decision dated December 20, 2005 (CA-G.R.-CR No. 27544), affirmed the RTC decision in toto.
- Petitioner’s Motion for Reconsideration was denied by the appellate court in a Resolution dated March 13, 2006.
- Petitioner filed a petition for certiorari under Rule 45 before the Supreme Court, raising factual and legal challenges to his conviction and the award of damages.
Facts
- On September 26, 1999, petitioner and companions (Fidel Foz, Jr. and Armando Foz) had a loud videoke drinking session near the home of Manuel K. Chy, who twice asked them to quiet down.
- Petitioner was overheard threatening Chy in Ilocano, expressing intent to “lay a hand on him” and later “finish him off.”
- On September 28, during a wedding celebration, petitioner again insulted Chy and vowed he would “not let him live long.”
- On September 29, the group reconvened; petitioner repeated threats against Chy and later, at a store, summoned the victim.
- Upon Chy’s approach, petitioner struck him with a closed fist, continued to assault him despite Chy’s protestations, and then used a beer bottle to deliver a blow to the back of Chy’s head.
- Chy managed to escape, summoned his wife, and reported breathing difficulty; police and his wife found him unconscious, and he was pronounced dead on arrival at the hospital.
- Autopsy determined cause of death as myocardial infarction, with multiple contusions, a laceration of the upper lip, coronary artery narrowing, myocardial fibrosis, pulmonary edema, and other findings.
Issue
- Whether petitioner can be held criminally liable for the death of Manuel K. Chy, notwithstanding that the