Case Summary (G.R. No. 205487)
Factual Antecedents
On October 1, 1996, a charge of homicide was lodged against the petitioner, alleging that on November 25, 1995, in Gonzaga, Cagayan, he intentionally assaulted Lucrecio Seguritan, causing fatal head injuries. During trial, it was established that the petitioner and the victim were engaged in a drinking session, during which a dispute arose over agricultural damage allegedly caused by the victim's carabao. The altercation escalated into physical violence, leading to the victim falling and suffering severe head injuries. Despite efforts to revive him, Lucrecio succumbed to his injuries later that night. An autopsy confirmed the death was due to traumatic head injuries.
The Version of the Prosecution
The prosecution presented evidence that the petitioner had punched Lucrecio, causing him to fall and hit his head. Witness accounts noted that the victim was incapacitated, and the autopsy revealed significant head trauma. Testimony from Dr. Antonio Vertido, who conducted the autopsy, confirmed that Lucrecio died from these injuries. Furthermore, discrepancies emerged about Lucrecio's alleged heart attack, as such claims did not hold against the established forensic evidence showing fatal head injuries.
The Version of the Defense
Contrarily, the petitioner denied hitting Lucrecio, asserting that Lucrecio's death resulted from a heart attack rather than from any assault. The defense attempted to introduce witness testimony suggesting that the victim's health issues were the cause of death, as indicated in the Certificate of Death. However, this assertion was countered by expert forensic findings.
Ruling of the Regional Trial Court
On February 5, 2001, the RTC convicted the petitioner of homicide, determining that he acted with intent and caused the victim's death through his actions. The court sentenced him to an indeterminate prison term of 6 years and 1 day as the minimum and 17 years and 4 months as the maximum, along with orders for damages to be paid to the victim’s heirs.
The Decision of the Court of Appeals
The CA upheld the RTC's conviction but modified the sentence to reflect an indeterminate range of 6 years and 1 day to 12 years and 1 day of reclusion temporal. The CA also increased the damages to include moral damages and affirmed the other financial awards. The petitioner’s subsequent motion for reconsideration was denied.
Issues Presented
In appealing the CA's decision, the petitioner asserted that the appellate court erred in affirming the RTC’s judgment and argued that the evidence pointed towards the accidental nature of the injuries rather than a clear intention to kill.
Our Ruling
The Supreme Court denied the petition. The Court affirmed the findings of both the RTC and CA regarding the nature of the injuries inflicted by the petitioner, finding sufficient evidence to support the homicide conviction. It also clarified that the act of violence and the resultant injuries warranted criminal liability irrespective of the absence of intent to kill
...continue readingCase Syllabus (G.R. No. 205487)
Factual Background
- The case revolves around RoAo Seguritan y Jara, who was charged with homicide for the death of his uncle, Lucrecio Seguritan.
- The incident occurred on November 25, 1995, during a drinking session in Gonzaga, Cagayan.
- A dispute arose over Lucrecio's carabao destroying RoAo's crops, leading to a physical altercation.
- RoAo admitted to punching Lucrecio twice, resulting in Lucrecio falling and sustaining head injuries.
- Lucrecio was initially revived but later died that night, leading to the investigation by the National Bureau of Investigation (NBI).
Prosecution's Version
- The prosecution presented evidence that RoAo punched Lucrecio, causing him to fall onto a hollow block and sustain fatal head injuries.
- An autopsy conducted by Dr. Antonio Vertido revealed significant injuries, including hematomas and a linear fracture in the skull, concluding that Lucrecio died from traumatic head injury.
- Testimony from witnesses, including Melchor Panis, supported the prosecution's assertion that RoAo's actions directly led to Lucrecio's death.
Defense's Version
- RoAo denied intentionally hitting Lucrecio, claiming that Lucrecio's fatal injuries were due to a heart attack.
- The defense presented witnesses to assert that Lucrecio had a preexisting heart condition, which supposedly contributed to his death.
- The defense argued that Lucrecio's injuries occurred as a result of falling from the bench rather than from RoAo's punches.
Ruling of the Regional Trial Court (RTC)
- On Februar