Title
People vs. Orlito Villacorta
Case
G.R. No. 186412
Decision Date
Sep 7, 2011
Orlito Villacorta was convicted of murder for stabbing Danilo Cruz, but the Supreme Court reversed the decision, finding him guilty of slight physical injuries instead, citing a lack of intent to kill and intervening causes for Cruz's death.

Case Summary (G.R. No. 186412)

Facts of the Case

On January 23, 2002, at approximately 2:00 AM, Orlito Villacorta allegedly stabbed Danilo Cruz with a sharpened bamboo stick outside a sari-sari store operated by Cristina Mendeja in Navotas. Mendeja, a prosecution witness, testified that Villacorta attacked Cruz suddenly and without warning, inflicting serious wounds that led to Cruz’s immediate injury. The bamboo stick used broke and became embedded in Cruz’s body. Villacorta fled immediately after the stabbing. Mendeja and a neighbor named Aron took Cruz to Tondo Medical Center for treatment.

Medical Evidence and Cause of Death

Dr. Domingo Belandres, Head of the Tetanus Department at San Lazaro Hospital, testified based on Cruz’s medical charts and diagnosis. Cruz was initially treated as an outpatient at Tondo Medical Center, then admitted to San Lazaro Hospital on February 14, 2002, where he died the following day from tetanus infection secondary to the stab wound. The doctor described the progression of symptoms—including difficulty opening the mouth and hypoxic encephalopathy—and diagnosed severe tetanus (Stage III) as the cause of death. The prosecution and defense stipulated that testimony from Dr. Deverni Matias, who also treated Cruz, was unnecessary as it would only corroborate Dr. Belandres’s findings.

Accused’s Defense

Villacorta denied stabbing Cruz, admitting only to a non-lethal physical altercation where he boxed Cruz after being embraced. He claimed no knowledge of any injury caused to Cruz and asserted that he only learned of Cruz’s death upon arrest. Villacorta challenged the credibility of Mendeja’s testimony, raising several alleged inconsistencies including Mendeja’s reaction during the stabbing, the involvement of other witnesses, and contradictions regarding the location of the bamboo stick.

Trial Court’s Findings

The RTC convicted Villacorta of murder with the qualifying circumstance of treachery and sentenced him to reclusion perpetua, as well as civil indemnity to Cruz’s heirs. The court gave full credence to Mendeja’s testimony, finding her identification of Villacorta as the assailant reliable, supported by her familiarity with both victim and accused, the presence of light, and the specifics of the incident’s timing and location. The court also recognized treachery based on the suddenness and surprise of the attack preventing any defense or retaliation.

Court of Appeals’ Affirmation

The Court of Appeals affirmed the RTC decision in toto, dismissing Villacorta’s arguments against Mendeja’s credibility. It explained that human reactions to witnessing a crime vary and that other persons’ failure to act did not invalidate Mendeja’s account. The Court also noted the improbability of Villacorta’s denial in light of witness testimony and the lack of motive for fabrication.

Supreme Court’s Review and Legal Analysis

The Supreme Court deferred to the findings of fact of both the RTC and Court of Appeals on witness credibility, emphasizing the trial court’s superior position to assess demeanor and veracity. The Court ruled that inconsistencies cited by Villacorta were not material enough to create reasonable doubt. It held that Mendeja’s eyewitness account, coupled with Villacorta’s partial admission of physical contact, sufficed to establish guilt for physical injuries.

Proximate Cause of Death and Medical Considerations

Despite affirming the stabbing, the Supreme Court found that the proximate cause of Cruz’s death was tetanus infection, not the stab wound itself. Applying the principle of proximate cause—that the cause must be the direct, natural, and continuous sequence leading to injury without efficient intervening causes—the Court considered Cruz’s medical treatment and the delay of 22 days before tetanus symptoms appeared. Since tetanus typically manifests within 14 days, with severe cases emerging within 2-3 days, the Court concluded that the infection was an efficient intervening cause independent of the stabbing injury.

Precedential Comparison (Urbano v. Intermediate Appellate Court)

The Court relied heavily on Urbano v. Intermediate Appellate Court, a case with strikingly similar facts involving death from tetanus infection following a wound inflicted during an altercation. There, the Court acquitted the accused of homicide due to intervening causes related to the victim’s own negligence and medical circumstances, emphasizing the necessity of proving direct causation beyond reasonable doubt in homicide cases. The present case mirrored these concerns and was resolved accordingly.

Reclassification of Offense and Sentence Imposed

Given the absence of evidence establishing Villacorta’s intent to kill, the Court determined that the charge of murder could not stand. Nor did the facts support attempted or frustrated murder, as only a single, non-lethal wound was inflicted and no immediate incapacitation occurred. The proper charge was slight physical injuries under Article 266 (1) of the Revised Penal Code, punishable by arresto menor (one to thirty days of imprisonment). The qualifying circumstance of treachery was upheld, permitting the imposition of the maximum penalty within arresto menor.

Final Disposition and Award of Damages

The Supreme Court reversed and set aside the murder conviction and re-sentenced Villacorta to thirty days of arresto menor. Considering Villacorta’s prolonged det

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