Case Summary (G.R. No. L-52797)
Facts of the Case
On January 8, 1977, Amparo Lazo y Villaflor, a 76-year-old woman, suffered a stroke that left her in a coma and requiring immediate medical attention. She was rushed to the Polymedic General Hospital where she was admitted in critical condition. Doctors attempted to stabilize her using various medical procedures, including the insertion of an endotracheal tube. Despite this, Angelo Umaguing, a janitor at the hospital, unlawfully removed the tube after the doctors had left, resulting in severe complications for the patient.
Incident and Medical Response
Umaguing's actions, witnessed by several individuals, caused Lazo to convulse and bleed from the mouth. Medical personnel were alerted, and the tube was reinserted, but Lazo’s condition remained grave, prompting her transfer to Cardinal Santos Memorial Hospital, where she subsequently died from cardiorespiratory arrest the following day.
Legal Proceedings
Following Lazo’s death, the Mandaluyong police initiated an investigation which led to the filing of murder charges against Umaguing. The Circuit Criminal Court convicted him of consummated murder with several aggravating circumstances, ultimately imposing the death penalty, which was then elevated for review.
Defense Claims and Court Findings
During the trial, Umaguing testified that he was instructed by Dr. Sison to remove the tube, a claim denied by Dr. Sison. His defense hinged on claims that the critical nature of the victim’s condition meant her death was inevitable, thus negating intent. However, the court found that Umaguing had no lawful reason to be at the emergency room during the procedure and acted with malicious intent when he removed the tube, which constituted an attempt on the victim's life.
Court’s Conclusion on Intent and Legal Outcome
The court determined that Umaguing's conduct was not accidental but purposeful, indicating a malignant intention. The trial court’s original findings were modified to reflect that while the defendant’s actions constituted att
...continue readingCase Syllabus (G.R. No. L-52797)
Case Overview
- The case involves Angelo Umaguing, a janitor, accused of attempting to hasten the death of a 76-year-old woman, Amparo Lazo y Villaflor, who was critically ill after suffering a stroke.
- The incident occurred on January 8, 1977, at Polymedic General Hospital in Quezon City.
Factual Background
- Amparo Lazo experienced severe headache, vomiting, and subsequently fell into a coma due to cerebro-vascular congestion.
- On arrival at the hospital, she was in critical condition, with high blood pressure and difficulty breathing, and was treated with multiple medications.
- An endotracheal tube was inserted to assist her breathing, a procedure witnessed by medical staff and relatives.
The Incident
- Shortly after the insertion of the endotracheal tube, Umaguing removed the plaster that secured the tube, an act witnessed by relatives and medical personnel.
- This action caused Amparo to bleed and convulse, prompting immediate medical intervention.
- Umaguing attempted to close the patient's eyes, indicating a malicious intent, while the medical staff were alerted, leading to his apprehension by security.
Investigation and Charges
- Following Amparo's transfer to ano