Case Summary (G.R. No. 213792)
Incident Facts and Prosecution Version
On April 11, 2004, at Ambongdolan, Tublay, Benguet, Edward Benito witnessed petitioners, in conspiracy, attack Elner Aro by kicking him in the abdomen and attempting to throw a rock. Quibac later punched Aro’s stomach, causing collapse and severe internal injuries. Aro was subsequently taken to the hospital.
Medical Treatment and Determination of Cause of Death
At the hospital, Aro was diagnosed with blunt abdominal trauma and injury to the jejunum. Surgery revealed a perforated ileum and generalized peritonitis. He suffered cardiac arrest intraoperatively, lapsed into a coma, and was discharged against medical advice due to financial constraints. He died the following day. The death certificate cited cardiopulmonary arrest secondary to perforated ileum, while autopsy attributed death to aortic rupture from blunt trauma.
Defendants’ Account and Defense Claims
Petitioners denied intent to kill, claiming that Aro was drunk and unruly. They asserted that Wacoy only picked up a stone to threaten Aro and that Quibac intervened to prevent further violence. They maintained that any physical contact arose from Aro’s aggression, that only limited force was used, and that there was no conspiracy to kill.
Trial Court’s Judgment and Rationale
The Regional Trial Court of Benguet convicted petitioners of Death Caused in a Tumultuous Affray under Article 251 of the RPC. It held that conspiracy to kill was unproven and that medical evidence did not conclusively link the mauling to death. Petitioners were sentenced to six months and one day of prision correccional as minimum to eight years and one day of prision mayor as maximum, with awards of temperate, moral, and civil indemnity damages.
Court of Appeals’ Modification to Homicide
The Court of Appeals reversed the RTC’s classification, finding only two assailants and no “tumultuous” group violence. It convicted petitioners of Homicide under Article 249 with the mitigating circumstance of lack of intent to commit so grave a wrong, imposing an indeterminate term of six years and one day of prision mayor as minimum to twelve years and one day of reclusion temporal as maximum. It also increased legal interest on damages to six percent per annum.
Supreme Court’s Issue for Resolution
The sole issue before the Supreme Court was whether the CA correctly found petitioners guilty of Homicide beyond reasonable doubt, rather than the lesser crime of Death Caused in a Tumultuous Affray.
Classification of Homicide versus Tumultuous Affray
The Supreme Court agreed that the affray provisions did not apply: only two persons targeted a single victim in a non-reciprocal attack. Article 251 requires several combatants engaging in confused mutual assault where the killer is unidentifiable. Conversely, Article 249’s elements of Homicide were met: Aro was killed without justification, intent to kill was presumed, and no qualifying circumstances for Murder were present.
Assessment of Intent and Mitigating Circumstances
Petition
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Facts of the Case
- On April 11, 2004, at around 3:00 PM in Ambongdolan, Municipality of Tublay, Benguet, petitioners Guillermo Wacoy y Bitol and James Quibac y Rafael allegedly conspired to kill Elner Aro y Laruán.
- Prosecution witness Edward Benito testified he saw Aro sprawled on the ground, then observed Wacoy deliver two kicks to Aro’s stomach, attempt to throw a rock (which was restrained), and Quibac punch Aro in the stomach, causing his collapse.
- Aro was taken to the hospital and diagnosed with blunt abdominal trauma, perforation of the ileum, generalized peritonitis, and air and fluid in the peritoneum. He suffered cardiac arrest during surgery, lapsed into coma, was removed against medical advice for financial reasons, and died the following day.
- Aro’s death certificate cited “cardiopulmonary arrest antecedent to a perforated ileum and generalized peritonitis secondary to mauling,” while autopsy findings attributed death to “rupture of the aorta secondary to blunt traumatic injuries.”
- Petitioners denied homicidal intent, claiming they had merely sought to restrain or defend against an unruly, drunk Aro who had kicked a pool table and threatened them with a wooden plank.
Procedural History
- June 10, 2004: Information filed in the Regional Trial Court (RTC) of Benguet, Branch 10, charging petitioners with homicide under Article 249 of the Revised Penal Code, attended by the aggravating circumstance of superior strength.
- February 28, 2011: RTC rendered judgment finding petitioners guilty of Death Caused in a Tumultuous Affray (Art. 251, RPC), sentencing them to 6 months & 1 day to 8 years & 1 day of imprisonment and ordering payment of temperate, civil indemnity, and moral damages.
- December 6, 2013: Court of Appeals (CA) modified the conviction to Homicide (Art. 249, RPC) with the mitigating circumstance of lack of intent to commit so grave a wrong, adjusted the penalty to 6 years & 1 day to 12 years & 1 day, and imposed 6% interest on damages.
- July 21, 2014: CA denied petitioners’ motions for reconsideration.
- Petitioners filed consolidated petitions for certiorari before the Supreme Court.
Issue Presented
- Whether the Court of Appeals c