Seguritan vs. People

A person committing an unlawful felony is criminally liable for the resulting homicide even if the wrongful act done is different from that intended, pursuant to Article 4 of the Revised Penal Code. Furthermore, documentary evidence not formally offered in court cannot be considered, and actual damages unsupported by receipts must be replaced by temperate damages.

Petitioner Roño Seguritan and his uncle, Lucrecio Seguritan, were engaged in a drinking session on November 25, 1995, when a dispute arose over the latter's carabao destroying the former's crops. Petitioner punched Lucrecio twice, causing the victim to fall and hit his head on a hollow block. Lucrecio lost consciousness but eventually went home, slept, and died later that night. The victim's wife later learned of the petitioner's involvement and sought an NBI investigation, leading to an exhumation and autopsy that attributed the death to traumatic head injury. Petitioner denied throwing the punches, claimed the victim fell accidentally, and contended the death was caused by a heart attack, as indicated on the death certificate.

• The Altercation: On November 25, 1995, petitioner and his uncles, including victim Lucrecio Seguritan, were drinking at a neighbor's house. A heated argument ensued after petitioner claimed Lucrecio's carabao destroyed his crops. As Lucrecio was about to stand up, petitioner punched him twice on the temples, causing him to fall face-up and hit his head on a hollow block used as an improvised stove.
• The Victim's Death: Lucrecio lost consciousness but was revived. He took a tricycle home, went to sleep, and died around 9:00 PM that night. His wife noticed blood on his forehead and a darkened complexion with foam coming from his mouth.
• The Autopsy: After burial, the NBI exhumed the body. Medico-legal officer Dr. Antonio Vertido found hematomas in the scalp, a linear fracture in the right middle fossa, and a subdural hemorrhage, concluding that the cause of death was traumatic head injury.
• The Defense's Version: Petitioner claimed he merely stood up to punch Lucrecio, but the victim lost his balance and fell before being hit. To prove the cause of death was a heart attack, the defense presented the Certificate of Death, which listed "T/C cardiovascular disease" as the antecedent cause. The physician who signed it, Dr. Corazon Flor, testified she did not examine the cadaver but relied on the informant's statement. Petitioner also cited a legal medicine textbook claiming that the one-month delay in the autopsy and the embalming of the body compromised the autopsy results.

• Causation and Cause of Death: Petitioner argued that the head fracture was caused by the victim's fall, not by the fist blows, and that the victim died of cardiac arrest. He maintained the CA overlooked material facts, specifically that the autopsy was compromised by a one-month delay and embalming, rendering the results unreliable.
• Lack of Intent to Kill: Petitioner contended that absent intent to kill, he should only be held liable for reckless imprudence resulting in homicide, not intentional homicide.
• Evidentiary Weight of Autopsy: Petitioner asserted that the medico-legal findings were unworthy of credence due to the embalming and delay, relying on a legal medicine textbook.

• Causation: Respondent maintained that the eyewitness account of the punching was consistent with the medico-legal findings, proving that the fist blows caused the fatal head injuries.
• Cause of Death: Respondent argued that the death certificate was unreliable because the signing physician did not examine the body, whereas the medico-legal officer who performed the autopsy categorically ruled out a heart attack based on gross examination of the heart.
• Admissibility of Evidence: Respondent countered that the legal medicine textbook cited by petitioner could not be considered because it was never formally offered in evidence.

• Factual Findings and Cause of Death: Whether the Court of Appeals erred in affirming the trial court’s judgment of conviction by overlooking material factual matters regarding the cause of death and the validity of the autopsy.
• Proper Crime Charged: Whether the Court of Appeals erred in convicting the accused of homicide instead of reckless imprudence resulting in homicide given the alleged lack of intent to kill.

• Factual Findings and Cause of Death: The conviction was affirmed because the trial court did not overlook any material facts. The eyewitness testimony of the victim's brother corroborated the medico-legal findings that the fist blows caused the fatal head injuries. The defense's claim of a heart attack was rejected, as the death certificate was executed without examining the cadaver, while the medico-legal officer found no cardiac abnormalities. The argument that the autopsy was compromised by delay and embalming was disregarded because the legal medicine textbook supporting this claim was not formally offered in evidence, depriving the prosecution of the opportunity to object and the court of the chance to examine it.
• Proper Crime Charged: Homicide was the correct conviction. Under Article 4 of the Revised Penal Code, criminal liability is incurred by any person committing a felony although the wrongful act done be different from that which he intended. Punching an older uncle is an unlawful act; thus, the aggressor is responsible for all the natural consequences thereof, including death, even absent intent to kill.

• Article 4, Revised Penal Code (Proximate Cause) — Criminal liability shall be incurred by any person committing a felony although the wrongful act done be different from that which he intended. Applied to hold petitioner liable for homicide resulting from the unlawful act of punching the victim, despite the lack of intent to kill.
• Formal Offer of Evidence — Courts will only consider as evidence that which has been formally offered by the parties at trial. A judge must base findings strictly on the evidence offered; otherwise, the opposing party is deprived of the chance to examine and object. Applied to exclude the legal medicine textbook cited by the defense.
• Temperate Damages — When pecuniary loss has been suffered but the amount cannot be proven with certainty, temperate damages may be recovered. Applied to substitute the award of actual damages, which lacked supporting receipts, with temperate damages of ₱25,000.00.

• "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."
• "Any evidence which a party desires to submit to the courts must be offered formally because a judge must base his findings strictly on the evidence offered by the parties at the trial."

• United States v. Gloria, 3 Phil. 333 (1904) — Followed. Cited for the rule that in crimes of personal violence, the penal law looks to the material results following the unlawful act and holds the aggressor responsible for the consequences, even absent intent to kill.
• Candido v. Court of Appeals, 323 Phil. 95 (1996) — Followed. Cited for the rule that courts will only consider as evidence that which has been formally offered, and failure to do so deprives the opposing party of the right to object.

• Article 4, Revised Penal Code — Provides that criminal liability is incurred by any person committing a felony although the wrongful act done be different from that which he intended. Applied to establish liability for homicide despite the lack of intent to kill, as the unlawful act of punching resulted in death.
• Article 249, Revised Penal Code — Prescribes the penalty of reclusion temporal for homicide. Applied as the basis for the penalty imposed, which was modified by the Indeterminate Sentence Law and the mitigating circumstance of no intention to commit so grave a wrong.
• Rule 132, Section 34, Rules of Court — Requires a formal offer of evidence. Applied to justify the exclusion of the legal medicine textbook that the defense failed to formally offer during trial.

Antonio T. Carpio (Chairperson), Arturo D. Brion, Roberto A. Abad, Jose Portugal Perez