Case Summary (G.R. No. L-204)
Case Background and Charges
Cornel was sentenced to an indeterminate prison term ranging from 8 years and 1 day of prision mayor to 14 years, 8 months and 1 day of reclusion temporal, along with accessory penalties. He was also ordered to indemnify Burac's heirs in the amount of P2,000 and cover the associated costs. The appeal presented primarily questioned the sufficiency of the evidence related to Cornel's identity as the assailant.
Evidence and Witness Testimony
The core of the prosecution's case rested on the eyewitness testimony of Trinidad Coral, who observed Cornel assaulting Burac with a bolo as Burac descended his stairs on June 8, 1945. Coral testified that after wounding Burac, Cornel threw a stone that struck Burac's clavicle and then fled toward his residence. The trial court accorded full credibility to Coral's account, emphasizing her familiarity with the appellant, which countered Cornel’s conjecture regarding potential misidentification.
Identity of the Assailant
The identification of Cornel was further corroborated by an additional witness, Caspara Bendicio, who reportedly received a declaration from Burac shortly after the attack, wherein Burac attributed his injuries to Cornel. Despite Cornel's assertion that this testimony was inadmissible, it was upheld by the trial court under the res gestae principle, further solidifying Cornel's identity as the perpetrator.
Forensic Evidence and Medical Testimony
Cornel's defense sought to challenge the nature of Burac’s injuries based on the medical testimony provided by Dr. Mariano Cruel. Dr. Cruel described an incised vertical wound on Burac's forehead, attributing it to a bolo or similar weapon. Cornel contended that the wound could have been caused by a hard irregular object, which, though theoretically plausible, lacked sufficient evidential support when weighed against eyewitness accounts.
Establishment of Death
The prosecution successfully established that Burac had indeed died as a result of tetanus stemming from the inflicted wounds. Testimony from Burac's wife and mother-in-law supported this claim, which was substantiated by Dr. Cruel's examination notes detailing the symptoms indicative of tetanus. The absence of a registration record with the civil registrar did not undermine the established fact of Burac’s death, as it merely indicated a lapse in documentation at that time.
Natural Consequences of the Act
The court concluded that Cornel must be held accountable for the direct consequences of his unlawful actions. It referenced previous jurisprudence (People vs. Borbano) emphasizing the liability that arises from the perpetration of a crim
...continue readingCase Syllabus (G.R. No. L-204)
Case Citation
- 78 Phil. 458
- G.R. No. L-204
- Date of Decision: May 16, 1947
Court and Justices
- Court of First Instance of Albay
- Decision rendered by Justice Paras
- Concurrence by Justices Pablo, Perfecto, Bengzon, Hontiveros, and Tuason
Facts of the Case
- The defendant, Gerardo Cornel, was convicted of homicide and sentenced to an indeterminate prison term ranging from 8 years and 1 day of prision mayor to 14 years, 8 months, and 1 day of reclusion temporal.
- The court ordered the defendant to pay P2,000 in indemnity to the heirs of the deceased, Fabian Burac, and to cover the costs of the trial.
- The incident occurred on June 8, 1945, in San Miguel, Tabaco, Albay, where the defendant allegedly assaulted the victim with a bolo as the latter was descending the stairs of his house.
Evidence Presented
- Trinidad Coral, the wife of the deceased, testified that she witnessed the defendant attack her husband with a bolo.
- Following the initial assault, the defendant threw a stone at the victim, hitting him on the right clavicle.
- The defendant fled the scene towards his residence after the attack.
- The trial court placed significant weight on Trinidad's testimon