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People vs. Reloj

The appeal was denied and the conviction for murder affirmed, with modification of the penalty from life imprisonment to an indeterminate sentence of 10 years and 1 day of prision mayor to 17 years, 4 months and 1 day of reclusion temporal. The accused stabbed the victim suddenly from behind with an ice pick at a cockpit in Aklan; the victim survived surgery but died five days later from paralytic ileum, a known complication of abdominal surgery. The Court found treachery present in the sudden attack, rejected the defense of incomplete self-defense as unworthy of credence, held the accused responsible for the death as a natural consequence of his felonious act, and recognized voluntary surrender as a mitigating circumstance warranting the minimum penalty.

Primary Holding

An accused who inflicts a wound with a deadly weapon upon a vital part of the body is responsible for the victim's death even where a medical complication supervenes, provided the complication is a natural consequence of the injury or the surgery necessitated by it; and where voluntary surrender is established as a mitigating circumstance with no aggravating circumstance to offset it, the penalty for murder must be imposed in its minimum period.

Background

Pablo Reloj was charged with the murder of Justiniano Isagan Sr. before the Court of First Instance of Aklan. The victim had previously been a witness against Reloj in a criminal case (later dismissed) and a civil case filed by Crisanta Ureta and Edecio Venturanza, which provided a possible motive for the killing. The case reached the Supreme Court on appeal from the lower court's judgment of conviction.

History

  1. An information for murder was filed against Pablo Reloj before the Court of First Instance of Aklan following the stabbing of Justiniano Isagan Sr. on July 7, 1963, and the latter's subsequent death.

  2. The Court of First Instance of Aklan rendered a judgment of conviction, sentencing Reloj to life imprisonment, with accessory penalties, and ordering him to indemnify the heirs of the victim in the sum of P12,000, without subsidiary imprisonment in case of insolvency and without costs.

  3. Reloj appealed to the Supreme Court, assigning eight errors covering witness credibility, intent to kill, causation, treachery, self-defense, mitigating circumstances, and the penalty imposed.

Facts

On July 7, 1963, at about 3:00 p.m., Justiniano Isagan Sr. was stabbed by Pablo Reloj with an ice pick wrapped in a piece of paper outside the cockpit in Libtong, Barrio of Estancia, Municipality of Kalibo, Province of Aklan. Soon thereafter, the victim was brought to the Aklan Provincial Hospital, where a surgical operation was performed upon him. Although the operation was successful and the victim appeared to be recovering, he developed a paralytic ileus five days later — a condition that sometimes occurs as a consequence of the exposure of internal organs during surgery — and then died.

The prosecution's principal evidence consisted of the testimony of Justiniano Isagan Jr. and Hermie Zante, as well as the ante-mortem declaration of the deceased. Justiniano Jr. testified that he and his father went to the cockpit at about 3:00 p.m.; that while his father stood under a mango tree outside the cockpit watching Hermie Zante tie a gaff on a fighting cock, the appellant approached from behind, placed his right hand on the victim's left shoulder, and stabbed him in the left side of the abdomen with an ice pick wrapped in paper. As Justiniano Jr. tried to approach his father, appellant rushed at him saying, "And you also," prompting the son to flee. The appellant soon gave up the chase, threw away the ice pick, and went to a nearby store where a policeman later arrested him. Justiniano Jr. returned to where his father was wounded and picked up the ice pick along the way. Hermie Zante corroborated this account, stating that while he was arming the fighting cock with the victim watching about one and a half brazas away, he heard the victim groan and saw the victim holding the appellant's left hand, which held an ice pick pointed at the victim's belly. The appellant then wrested himself free and chased Justiniano Jr. The ante-mortem declaration, Exhibit E, taken by Police Sergeant Angelo Villanueva at the hospital at about 4:00 p.m. on the same day, confirmed that the appellant had stabbed the victim suddenly in the abdomen with a weapon covered by paper, which turned out to be an ice pick, and that the appellant likewise tried to attack Justiniano Jr.

The prosecution further introduced testimony establishing motive. Rogelio Ibardolaza testified that at about 10:00 a.m. on the same day, he was in the store of one Ricamonte in Daguitan, Madalag, Aklan, where the appellant was drinking beer with two companions; he heard the appellant say he would first kill Justiniano Sr. and then go to Muntinglupa. Angel de la Cruz testified that at noontime, while aboard a truck headed for the cockpit, he heard the appellant tell his companion that he was going to kill Justiniano Sr.; the companion advised him to "cool off," and the appellant replied, "Ah, linti, this Isagan, they interfere with what is not theirs." De la Cruz alighted in front of the cockpit and went to the victim's house to warn him, but was told the victim was already at the cockpit; when he arrived at the cockpit at about 3:00 p.m., the victim had already been wounded and taken to the hospital.

Testifying in his own behalf, the appellant contradicted the prosecution witnesses and stated that from 5:00 a.m. to 1:00 p.m. on July 7, 1963, he was at his store in the market of Kalibo; that he left for the cockpit around 1:00 p.m.; that at about 2:30 p.m., he and the victim bet P10 against each other and he won; that when he demanded payment, the victim got mad and delivered several fist blows, which he did not return; and that when he was almost groggy, he drew the ice pick from his pocket and stabbed the victim in the belly. He then threw the ice pick away, proceeded to a nearby store, and voluntarily surrendered to a policeman. Dr. Luvisminda Kapunan, who examined the appellant on July 8, 1963, testified that the contusions and abrasions on the appellant's face and hand had been caused over 48 hours before the examination, or prior to July 7, 1963, thereby contradicting the appellant's claim that the injuries were inflicted by the victim on the day of the stabbing.

Arguments of the Petitioners

  • Credibility of Prosecution Witnesses: Appellant maintained that the lower court erred in giving full credence to the testimony of the main prosecution witnesses, asserting that his own version of events — that the victim attacked him first with fist blows over an unpaid bet — was the true account.
  • Lack of Intent to Kill: Appellant argued that he had no intent to kill, claiming the stabbing was a reaction to being battered by the victim.
  • Causation of Death: Appellant contended that he should not be held responsible for the death of Justiniano Sr. because the immediate cause of death was paralytic ileum, which supervened five days after the stabbing when the victim appeared to be recovering.
  • Qualifying Circumstance of Treachery: Appellant asserted that the crime was not murder qualified by treachery.
  • Incomplete Self-Defense: Appellant invoked the special mitigating circumstance of incomplete self-defense, claiming the victim had initiated the aggression.
  • Lack of Intent to Commit So Grave a Wrong: Appellant argued for the mitigating circumstance of lack of intent to commit so grave a wrong as that committed.
  • Voluntary Surrender: Appellant claimed the mitigating circumstance of voluntary surrender to the authorities.
  • Penalty: Appellant contended that the sentence of life imprisonment was excessive.

Issues

  • Credibility of Witnesses: Whether the lower court erred in giving full credence to the testimony of the prosecution's main witnesses.
  • Intent to Kill: Whether the appellant had intent to kill the victim.
  • Causation: Whether the appellant is responsible for the death of the victim despite the intervening medical complication of paralytic ileum.
  • Treachery: Whether the crime was murder qualified by treachery.
  • Incomplete Self-Defense: Whether the mitigating circumstance of incomplete self-defense applies.
  • Lack of Intent to Commit So Grave a Wrong: Whether the mitigating circumstance of lack of intent to commit so grave a wrong applies.
  • Voluntary Surrender: Whether the mitigating circumstance of voluntary surrender was properly established.
  • Penalty: Whether the penalty of life imprisonment was proper.

Ruling

  • Credibility of Witnesses: No. The lower court did not err; the appellant's version was inherently incredible and contradicted by medical evidence showing his injuries predated the incident.
  • Intent to Kill: No error. Intent to kill was established by the deadly nature of the weapon, the vital part of the body targeted, and the appellant's prior declarations of intent to kill.
  • Causation: No. The appellant is responsible for the death; paralytic ileum was a natural consequence of the abdominal surgery necessitated by the stab wound.
  • Treachery: No error. Treachery was present; the attack was sudden and from behind, giving the victim no opportunity to defend himself.
  • Incomplete Self-Defense: No. The claim was based on uncorroborated testimony unworthy of credence and inconsistent with the treachery of the attack.
  • Lack of Intent to Commit So Grave a Wrong: No. The circumstances evidencing intent to kill preclude this mitigating circumstance.
  • Voluntary Surrender: Yes. Voluntary surrender was established and constitutes a mitigating circumstance.
  • Penalty: No. Life imprisonment was improper; with no aggravating circumstance to offset the mitigating circumstance of voluntary surrender, the penalty should be imposed in its minimum period.

Ruling Rationale

  • Credibility of Witnesses: The appellant's version — that his demand for payment of a P10 bet so enraged the victim that the latter delivered fist blows causing contusions and abrasions — was inherently incredible. Dr. Kapunan, who examined the appellant on July 8, 1963, testified that the appellant's injuries had been caused over 48 hours prior to the examination, or before July 7, 1963, directly contradicting the appellant's account. Moreover, both Justiniano Jr. and Hermie Zante, who were only a few paces away, did not see any attack by the victim on the appellant; they testified that the appellant was not even present at the scene initially and appeared suddenly. Zante had no apparent motive to falsely incriminate the appellant, and his testimony was corroborated by the ante-mortem declaration of the deceased. The prosecution's theory was further bolstered by evidence that the appellant had declared his intent to kill the victim hours before the incident — once at a store in Daguitan and again on a truck headed for the cockpit — and that he had brought the ice pick with him wrapped in paper, indicating premeditation.

  • Intent to Kill: The deadly nature of the ice pick — with a blade almost five inches long — the targeting of a vital part of the body (the abdomen), the appellant's prior statements ("I will first kill him and then go to Muntinglupa"), and the manner of the attack left no room for doubt as to the appellant's intent to slay the victim.

  • Causation: Although the immediate cause of death was paralytic ileum that supervened five days after the stabbing when the victim appeared to be recovering, it was established that exposure of internal organs during abdominal surgery sometimes results in paralytic ileum, and that the surgery was necessitated by the abdominal wound inflicted by the appellant. Citing established doctrine, every person is held to contemplate and be responsible for the natural consequences of his own acts; if a person inflicts a wound with a deadly weapon and death follows as a consequence, it does not diminish criminality that other causes cooperated in producing the fatal result. A contrary rule would tend to give immunity to crime.

  • Treachery: The attack was made suddenly from behind, with the appellant placing his right hand on the victim's left shoulder before stabbing him, giving the victim no opportunity to defend himself. This satisfied the elements of treachery.

  • Incomplete Self-Defense: The claim of incomplete self-defense was predicated on the appellant's uncorroborated testimony, which was unworthy of credence and inconsistent with the treacherous manner of the attack. There was no credible evidence of unlawful aggression by the victim.

  • Lack of Intent to Commit So Grave a Wrong: The circumstances already found — the deadly weapon, the vital body part targeted, and the prior declarations of intent to kill — were sufficient to negate any claim of lack of intent to commit so grave a wrong.

  • Voluntary Surrender: It was established that the appellant had voluntarily surrendered to the authorities, warranting recognition of this mitigating circumstance.

  • Penalty: There being no aggravating circumstance to offset the mitigating circumstance of voluntary surrender, the penalty prescribed for murder should be imposed in its minimum period. The proper indeterminate penalty was from 10 years and 1 day of prision mayor to 17 years, 4 months and 1 day of reclusion temporal, with accessory penalties, costs, and the indemnity of P12,000 imposed by the lower court.

Doctrines

  • Responsibility for Natural Consequences of One's Acts — A person who inflicts a wound with a deadly weapon in a manner that puts life in jeopardy is responsible for the victim's death even if other causes, including medical complications such as paralytic ileum resulting from surgery, cooperated in producing the fatal result. The rule rests on practical policy: a contrary doctrine would tend to give immunity to crime and remove an essential safeguard for human life. Neglect of the wound or unskillful treatment, being themselves consequences of the criminal act that might naturally follow, must be deemed to have been within the contemplation of the guilty party.

  • Treachery as a Qualifying Circumstance — Treachery is present when the attack is sudden and unexpected, made from behind, giving the victim no opportunity to defend himself. The deliberate and unexpected manner of the assault ensures the commission of the crime without risk to the assailant.

  • Mitigating Circumstance of Voluntary Surrender — When voluntary surrender is established and no aggravating circumstance offsets it, the penalty for the crime must be imposed in its minimum period, and the court must impose the corresponding indeterminate penalty.

Key Excerpts

  • "every person is to be held to contemplate and to be responsible for the natural consequences of his own acts. If a person inflicts a wound with a deadly weapon in such a manner as to put life in jeopardy, and death follows as a consequence of this felonious and wicked act, it does not alter its nature or diminish its criminality to prove that other causes cooperated in producing the fatal result." — This passage articulates the ratio decidendi on causation: the accused remains criminally responsible for the victim's death despite the supervening medical complication, because the complication was a natural consequence of the injury he inflicted.

  • "A different doctrine would tend to give immunity to crime and to take away from human life a salutary and essential safeguard. Amid the conflicting theories of medical men, and the uncertainties attendant upon the treatment of bodily ailments and injuries, it would be easy in many cases of homicide to raise a doubt as to the immediate cause of death, and thereby to open a wide door by which persons guilty of the highest crime might escape conviction and punishment." — This passage provides the policy rationale for the causation rule, explaining why intervening medical complications do not break the chain of criminal responsibility.

Precedents Cited

  • People vs. Quianzon, 62 Phil. 162 — The primary authority cited for the doctrine that a person is responsible for the natural consequences of his own acts, including medical complications that supervene as a result of treatment necessitated by the wound inflicted. The quotation in the decision is drawn from this case. Numerous other cases were cited in the footnote as additional support for the same proposition, including People vs. Piamonte, 94 Phil. 293; People vs. Buyco, 80 Phil. 58; People vs. Cornel, 78 Phil. 458; People vs. Rellin, 77 Phil. 1038; People vs. Moldes, 61 Phil. 1; People vs. Reyes, 61 Phil. 341; People vs. Cagoco, 58 Phil. 524; People vs. Almonte, 56 Phil. 54; U.S. vs. Diaz, 15 Phil. 123; U.S. vs. Escalona, 12 Phil. 4; U.S. vs. Luciano, 2 Phil. 96; People vs. Demiar, L-15130, May 31, 1960; and People vs. Martin, L-3002, May 23, 1951.

Provisions

  • Revised Penal Code, Article 248 (Murder) — The crime was qualified by treachery, one of the qualifying circumstances enumerated for murder. The penalty prescribed for murder was applied, as modified by the presence of the mitigating circumstance of voluntary surrender with no offsetting aggravating circumstance.
  • Indeterminate Sentence Law — Applied in fixing the modified penalty: a minimum of 10 years and 1 day of prision mayor to a maximum of 17 years, 4 months and 1 day of reclusion temporal, reflecting the imposition of the penalty in its minimum period due to the mitigating circumstance of voluntary surrender.

Notable Concurring Opinions

Reyes, J.B.L., Makalintal, Zaldivar, Castro, Fernando, Teehankee, Barredo, Villamor, and Makasiar, JJ., concurred.