Case Summary (G.R. No. 160341)
Facts of the Case
The facts established through the prosecution's evidence indicate that on the evening of September 28, 1993, Urbano and Tomelden, after consuming alcohol, had a heated exchange inside the compound of the Lingayen Water District. A fistfight ensued after Tomelden insulted Urbano, which culminated in Urbano delivering a punch that knocked Tomelden unconscious. Tomelden was subsequently taken to the LIWAD office and later to the hospital due to severe headaches and other complications. His condition deteriorated, and he died on October 10, 1993, from cardio-respiratory arrest secondary to cerebral concussion and resultant cerebral hemorrhage.
Ruling of the Regional Trial Court (RTC)
On April 30, 2001, the RTC found Urbano guilty of homicide under Article 249 of the Revised Penal Code. The court sentenced him to an indeterminate prison term of eight years and one day to seventeen years and four months and ordered him to pay the heirs of the victim PHP 50,000 in civil indemnity.
Ruling of the Court of Appeals (CA)
The CA affirmed the RTC's decision on January 25, 2008, while modifying the ruling to include an award of moral damages amounting to PHP 50,000. The CA maintained that the evidence established that Urbano's actions were the proximate cause of Tomleden's death.
Issues on Appeal
Urbano raised two primary issues before the Supreme Court: (I) the CA erred in affirming his conviction for homicide; and (II) the court failed to recognize mitigating circumstances, including lack of intent to kill and sufficient provocation by Tomleden.
The Court’s Ruling
The Supreme Court ruled in part favor of Urbano, acknowledging that the prosecution had indeed proven the elements of homicide. However, the Court found merit in Urbano’s claims regarding the mitigating circumstances. The Court pointed out that provocation was sufficient, as Tomleden's insults immediately preceded the fight, and it acknowledged Urbano's lack of intent to commit a grave wrong when he punched Tomleden.
Mitigating Circumstances
The Court recognized that two mitigating circumstances were present: (1) Urbano's lack of intention to commit a grave wrong, which was evidenced by his attempts to avoid the altercation and assist Tomleden after the fight; and (2) sufficient provocation from Tomleden, as established by witness accounts of Tomleden’s insulting remarks before the incident.
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Case Overview
- This case involves a petition for review under Rule 45 seeking to reverse the Decision dated January 25, 2008, of the Court of Appeals (CA) which affirmed with modification the April 30, 2001 Decision of the Regional Trial Court (RTC) in Lingayen, Pangasinan.
- The petitioner, Rodel Urbano, was found guilty of Homicide in Criminal Case No. L-5028.
Facts of the Case
- On September 28, 1993, in Barangay Poblacion, Lingayen, the petitioner and the victim, Brigido Tomelden, engaged in a heated altercation after a picnic.
- The altercation escalated into a fistfight, where Urbano delivered a "lucky punch" that caused Tomelden to fall unconscious and sustain injuries.
- Tomelden was hospitalized multiple times between September 29, 1993, and October 10, 1993, when he ultimately died from complications related to the injuries sustained during the fight.
- The autopsy revealed that Tomelden died from cardio-respiratory arrest due to cerebral concussion and cerebral hemorrhage caused by the mauling incident.
Ruling of the RTC
- On April 30, 2001, the RTC found petitioner guilty of Homicide under Article 249 of the Revised Penal Code, imposing a sentence of an indeterminate prison term of eight years and one day of Prision Mayor to seventeen years and four months of Reclusion Temporal, along with an indemnity of PHP 50,000 to the victim's heirs.