G.R. No. 172896 April 19, 2010
Lessons Applicable: intent
- November 25,1995: Roño Seguritan y Jara alias Ranio was having a drinking session with his uncles Lucrecio Seguritan (51 year old farmer), Melchor Panis and Baltazar Panis, in the house of Manuel dela Cruz. Ranio was seated beside Lucrecio as he claimed that Lucrecio’s carabao entered his farm and destroyed his crops which bun the heated argument. As Lucrecio was about to stand up, he punched him twice hitting him in the right and left temple causing him to fall face-up to the ground and hit a hollow block which was being used as an improvised stove causing him to fall face-up to the ground and hit a hollow block which was being used as an improvised stove. Lucrecio rode a tricycle home. His wife noticed blood on his forehead so he explained that he was stoned.
- November 25,1995 9pm: Lucrecio’s wife and daughter noticed that his complexion has darkened and foamy substance was coming out of his mouth as he slept. They tried to revive Lucrecio but failed.
- December 4, 1995: Lucrecio’s wife learned of the incident and requested the assistance of the NBI. NBI Medico-Legal Officer Dr. Vertido concluded that Lucrecio’s cause of death was traumatic head injury
- October 1, 1996: He was charged with Homicide
- Ranio presented Joel Cabebe, the Assistant Registration Officer of Gonzaga, Cagayan, and Dr. Corazon Flor, the Municipal Health Officer of Sta. Teresita, Cagayan, to prove that Lucrecio died of a heart attack
- RTC: homicide
- CA: Affirmed
- Ranio argued that he should be liable only for reckless imprudence resulting in homicide due to the absence of intent to kill Lucrecio
ISSUE: W/N Ranio is guilty of homicide even if there is no intent
HELD: YES. petition is DENIED. AFFIRMED penalty of six years and one day of prision mayor as minimum, to 12 years and one day of reclusion temporal as maximum with MODIFICATION that petitioner is further ordered to pay P25,000.00 as temperate damages in lieu of actual damages, and P50,000.00 as civil indemnity
- When death resulted, even if there was no intent to kill, the crime is homicide, not just physical injuries, since with respect to crimes of personal violence, the penal law looks particularly to the material results following the unlawful act and holds the aggressor responsible for all the consequences thereof.
- Article 4 of the Revised Penal Code provides
- 1. By any person committing a felony (delito) although the wrongful act done be different from that which he intended.
- Unlawful act - punching Lucrecio
- He who is the cause of the cause is the cause of the evil caused