Title
Supreme Court
People vs. Carmen
Case
G.R. No. 137268
Decision Date
Mar 26, 2001
Accused-appellants, lacking medical expertise, negligently conducted a "healing prayer" on a 13-year-old boy, resulting in his death. Convicted of reckless imprudence resulting in homicide.

Case Summary (G.R. No. 137268)

Allegations Against the Accused

The information filed against the accused-appellants alleged that on January 27, 1997, they conspired to kill Randy Luntayao by inflicting fatal injuries during a supposed “healing” ritual. The prosecution outlined the events in which Randy was restrained, submerged in water, physically assaulted, and ultimately stabbed, leading to his death.

Prosecution Evidence

Several witnesses testified to the abusive ritual performed on Randy. Key testimony came from Honey Fe Abella, a child who observed the scene, describing how the victim was forcibly held under water, struck, and stabbed by the accused. Additionally, evidence presented from Eddie Luntayao, Randy’s father, indicated that the accused exploited the family's belief in spiritual healing, resulting in their isolation during the assault.

Defense Strategy

The defense called upon various witnesses to argue that the actions of the accused were intended as a healing measure, rather than an act of murder. Ritsel Blase, who claimed to have witnessed the events, testified that Randy became unruly during the ritual but did not affirm that any harmful actions intended to cause death took place. The defense further presented medical professionals to assert that Randy's death was due to pneumonia, rather than direct violence.

Trial Court Decision

The trial court found the accused guilty of murder, emphasizing the qualifying circumstance of treachery. The court held that the actions taken by the accused were intentional and contributed to Randy's death, despite the lack of intent to kill. The presence of multiple assailants, the manner of the attack, and the resulting fatal injuries led to the conclusion that the accused should face severe penalties.

Appeal and Justifications

In appealing the trial court's decision, the accused-appellants contended that their actions, driven by a belief in faith healing, did not amount to murder but rather reckless imprudence resulting in homicide. They cited a lack of malicious intent and argued that the trial’s reliance on the presumption of criminal intent was erroneous, especially given their belief and the consent of the victim’s parents.

Resolution of the Appeal

The appellate court modified the trial court's judgment, concluding that the accused-appellants acted with rec

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