Case Summary (G.R. No. 255085)
Charges and Trial Court Ruling
Natalio Ilustre was charged with willfully and unlawfully striking Juan Magsino in the right hypochondriac region with a closed fist. This blow allegedly bruised Magsino's liver, leading to internal hemorrhage and subsequently his death. The trial court found Ilustre guilty of homicide but acknowledged the absence of intent to inflict so grave a harm, sentencing him to twelve years and one day of reclusion temporal, a ₱1,000 indemnity to the deceased's family, and costs.
Grounds for Appeal
The appellant raised several issues:
- Whether the blow was indeed delivered to the right hypochondriac region causing liver bruising.
- Whether, even if a contusion occurred, it directly caused Magsino's death.
- Whether doubt as to the cause of death should have reduced the conviction to a misdemeanor.
- Whether the lack of criminal intent warranted acquittal.
- Whether reasonable doubt should have led to the appellant’s acquittal.
Background of the Incident
The incident took place during the feast of St. John in the barrio of Canlurangbayan, Balayan. The traditional event involved a procession carrying a roasted pig, with Natalio Ilustre acting as the person in charge to manage the crowd. The victim, Juan Magsino, described as delicate and having incipient tuberculosis, attempted to take a piece of the barbecued pig and was chased and struck by Ilustre, who boxed him in the abdomen, causing Magsino to fall. He subsequently became ill and died that afternoon.
Medical Autopsy and Expert Testimonies
Autopsy was conducted by Doctors Jose Ilagan, Antonio Agoncillo, and Hermenegildo del Castillo. Doctors Ilagan and Agoncillo diagnosed bruising of the right anterior lobe of the liver with resultant internal hemorrhage as the cause of death, dismissing tuberculosis and heart disease as direct causes. Doctor Castillo was unable to conclude a definitive cause.
Dr. Sixto Roxas, hospital director, also testified, acknowledging that a blow could have killed Magsino, though death after only five hours would be rare given Magsino's delicate health with tuberculosis and heart dilation. Nonetheless, he agreed that the internal hemorrhage caused by the blow considerably contributed to Magsino’s death.
Medical Consensus and Cause of Death
Despite minor differences in opinion, the majority of medical experts agreed that the cause of death was the liver contusion and internal hemorrhage resulting from the blow administered by the defendant. The tuberculosis condition was not considered the direct cause of death.
Legal Analysis on Criminal Liability
The appellant's denial of the blow lacked credibility in view of evidence showing the punch struck M
...continue readingCase Syllabus (G.R. No. 255085)
Facts of the Case
- Natalio Ilustre, the appellant, was charged with homicide for striking Juan Magsino with a closed fist on the right hypochondriac region on or about June 24, 1929, in Balayan, Batangas.
- The blow bruised Magsino’s liver, causing internal hemorrhage which resulted in his death.
- The incident occurred during a festive procession known as St. John’s day, where Ilustre was assigned to direct the procession and prevent people from overeating the roasted pig being paraded.
- Juan Magsino, described as delicate and suffering from incipient tuberculosis, attempted to take some roasted pig, prompting Ilustre to run after him and punch him, causing Magsino to fall.
- Magsino became ill shortly after the incident and died in the afternoon of the same day.
Proceedings and Lower Court Decision
- Ilustre was tried in the Court of First Instance of Batangas and found guilty of homicide.
- The trial court sentenced him to twelve years and one day of reclusion temporal, ordered him to pay ₱1,000 indemnity to the family of the deceased, and to pay the costs.
- The court considered as a mitigating circumstance the absence of intent to cause so grave an evil as death.
- Ilustre appealed the decision, advancing arguments questioning the accuracy of the finding regarding the blow, the cause of death, the classification of the crime, and the presence of reasonable doubt.
Issues on Appeal
- Whether the blow dealt by the appellant was actually on the right hypochondriac region and whether it bruised the victim’s liver.
- Whether the liver contusion and internal hemorrhage caused by that blow were the direct cause of Magsino’s death.
- Whether, due to doubt in the cause of death, the conviction for homicide was proper or should have been downgraded to a lesser offense.
- Whether the absence of criminal intent justified acquittal.
- Whether the appellant was entitled to the benefit of the reasonable doubt.
Autopsy and Medical Evidence
- The autopsy was conducted by Dr. Jose Ilagan, assisted by Drs. Antonio Agoncillo and Hermenegildo del Castillo, all municipal phy