Case Summary (G.R. No. 87084)
Respondent
- People of the Philippines.
Key Dates
- Incident: May 5, 2011
- MTCC Decision: February 18, 2016
- RTC Decision: January 30, 2017
- CA Decision: September 12, 2018
- SC Decision: September 16, 2020
Applicable Law
- 1987 Philippine Constitution
- Revised Penal Code (RPC)
• Article 8 (Conspiracy)
• Article 252 (Physical injuries in a tumultuous affray)
• Article 265 (Less Serious Physical Injuries) - Jurisprudential guides (e.g., Wacoy v. People; Mupas v. People)
Background of the Case
Eduardo Lacson and five co-accused were charged in six separate informations for Attempted Homicide (RPC Art. 248) after a May 5, 2011 altercation between the Lacsons and the Santos family. The case was tried in the Municipal Trial Court in Cities (MTCC), elevated by appeal to the Regional Trial Court (RTC), then to the Court of Appeals (CA), and finally to the Supreme Court (SC).
Facts of the Incident
- A group of Santos family members (Gary, Arnold, Eliza, Joyce Ann) arrived home claiming they had been chased and stoned by some Lacsons.
- Arnold confronted Hernani and Elizer Lacson at the Lacsons’ house; Deborah handed Eduardo a steel pipe, which he used to strike Arnold’s head.
- The Lacsons then indiscriminately attacked Gary, Richard, Romeo, Albert, and Rommel Santos with steel pipes.
- Victims were rushed to Jose B. Lingad Memorial General Hospital; Dr. Duane P. Cordero diagnosed injuries requiring two to eight weeks of healing.
Procedural History
- MTCC (Branch 1, San Fernando): Found all Lacsons guilty not of Attempted Homicide but of Less Serious Physical Injuries (Art. 265, RPC) for four of the six cases; acquitted in two due to insufficient evidence of intent to kill; imposed arresto mayor (maximum) and ordered actual and legal damages.
- RTC (Branch 44, San Fernando): Affirmed MTCC decision in toto on January 30, 2017; denied motion for reconsideration.
- CA (CA-G.R. CR No. 40456): Dismissed Eduardo’s petition on September 12, 2018; denied reconsideration on December 18, 2018.
- SC: Denied petition for certiorari on September 16, 2020.
Issue on Review
Whether the CA erred in:
- Failing to establish Eduardo’s personal participation in inflicting injuries; and
- Concluding that conspiracy existed among the Lacsons.
Supreme Court’s Ruling
The petition is denied. The SC finds no reversible error in the appellate courts’ application of RPC Articles 252 and 265 and their determination of conspiracy under Article 8. Eduardo is guilty of four counts of Less Serious Physical Injuries.
Analysis on Tumultuous Affray vs Less Serious Physical Injuries
- Article 252 (tumultuous affray) applies when participants cannot be individually identified; triggers a reduced penalty if only less serious injuries result.
- Here, the assault was a deliberate, organized attack by the Lacsons on an identified group of victims; Eduardo was specifically seen striking Arnold and thereafter assaulting other Santos members.
- Intent to kill was not sufficiently proven; thus, the offense was downgraded to Less Serious Physical Injuries (Article 265), which requires incapacitation or medical assistance for ten days or more—established by Dr. Cordero’s testimony.
Conspiracy
- Under RPC Article 8, conspiracy may be proved by circumsta
Case Syllabus (G.R. No. 87084)
Parties and Nature of the Petition
- Petitioner: Eduardo Lacson y Manalo.
- Respondent: People of the Philippines.
- Nature: Petition for Review on Certiorari under Rule 45, challenging the CA Decision dated 12 September 2018 and Resolution dated 18 December 2018 in CA-G.R. CR No. 40456.
Facts of the Case
- Six (6) amended informations for Attempted Homicide were filed on 11 May 2011 against Eduardo and five co-accused (the Lacsons) before the MTCC of San Fernando, Pampanga.
- Victims: Gary Santos y Mallari; Rudy Santos y Lumba; Richard Santos y Mallari; Romeo Santos y Lumba; Albert Santos y Mallari; Rommel Santos y Mallari.
- Allegation: On 5 May 2011, the Lacsons, armed with steel pipes, conspired to attack and kill the six complainants, inflicted blows on various parts of their bodies in an apparent homicidal attempt, but were prevented from completing the crime by bystanders.
- All accused pleaded not guilty at arraignment.
Trial Proceedings and Evidence
- Prosecution presented six (6) witnesses: Rommel M. Santos; Gary M. Santos; Richard M. Santos; Rowena L. Santos-Cunanan; Romeo L. Santos; Dr. Duane P. Cordero (attending physician).
- Sequence of events:
• Evening of 5 May 2011, some Santos family members chased and stoned by Lacsons.
• Arnold Santos approached the Lacsons’ home and argued with Hernani and Elizer.
• Deborah Lacson handed a steel pipe to Eduardo, who struck Arnold’s head, then joined other Lacsons in attacking the remaining Santoses. - Injuries documented by Dr. Cordero:
• Periods of healing ranged from two (2) weeks to more than thirty (30) days, qualifying as “less serious physical inju