People v. Arranchado
REITERATIONFacts
The Antecedents: On July 10, 1957, Revilioso Ygot was with Leon Buangjug. Later, Ygot went to the house of Bonifacia Pepito. Less than half an hour later, Buangjug heard Ygot shout that he was beaten by Sergio Arranchado, Jose Tuico, and Miguel Arriesgado, and then stabbed by Marceliano Arranchado. Ygot ran but fell, and was carried home. To his father, Sergio Ygot, he declared he was beaten by Jose, Iyok (Jose), and Miguel, and stabbed by Marsing (Marceliano), stating he thought he would die. Ygot was taken for medical treatment, but expired upon arrival in the city. Dr. Augusto M. Lucero treated Ygot for a stab wound on the left thoracic wall, producing 'sucking pneumothorax,' and contusions on various parts of his body. The doctor certified that death was caused by severe blood loss from the stab wound. Procedural History: Appellants Sergio Arranchado, Jose Tuico, and Miguel Arriesgado, along with Marceliano Arranchado, were charged with homicide. The information was later amended to murder, alleging evident premeditation and treachery. Marceliano Arranchado pleaded guilty and was sentenced. The case proceeded against the other appellants. The Court of First Instance of Cebu found Sergio Arranchado, Jose Tuico, and Miguel Arriesgado guilty of murder, sentencing them to reclusion perpetua. The Petition: The accused-appellants appealed the decision of the Court of First Instance.
Issue(s)
Whether the accused-appellants are guilty of murder. Whether conspiracy was proven among the accused-appellants and Marceliano Arranchado. Whether the accused-appellants can be held liable as co-principals or accomplices to the murder. Whether the accused-appellants are guilty of slight physical injuries.
Ruling
The Supreme Court modified the decision of the Court of First Instance. It found the accused-appellants Sergio Arranchado, Jose Tuico, and Miguel Arriesgado guilty of slight physical injuries, penalized by the second paragraph of Article 266 of the Revised Penal Code, aggravated by superior strength. They were sentenced to 30 days imprisonment and ordered to indemnify the heirs of the deceased in the sum of P1,000.00.
Ratio Decidendi
On whether the accused-appellants are guilty of murder: The Court ruled that the accused-appellants were not guilty of murder. The evidence, including the dying declaration of the victim and the eyewitness testimony, indicated that the appellants inflicted blows with pieces of wood, causing contusions. However, the fatal stab wound was inflicted by Marceliano Arranchado, who appeared suddenly and acted separately. The medical certificate confirmed that the cause of death was severe blood loss from the stab wound, and the contusions were not fatal. Therefore, the appellants did not participate in the killing itself. On whether conspiracy was proven: The Court found no proof of conspiracy among the appellants and Marceliano Arranchado. The prosecution's evidence suggested that Marceliano Arranchado intervened only after the appellants had assaulted the deceased, and it did not appear that the appellants continued their attack thereafter. Both the victim's ante-mortem statement and the eyewitness testimony indicated that Marceliano's intervention was distinct and separate from the appellants' actions. The suddenness of Marceliano's attack further excluded any cooperation from the appellants in his homicidal act. On whether the accused-appellants can be held liable as co-principals or accomplices: The Court held that the appellants could not be held liable as co-principals because they did not take part in the killing itself, nor did they induce Marceliano to commit it, nor did they cooperate in its commission by another act without which it would not have been accomplished, pursuant to Article 17 of the Revised Penal Code. They also could not be held liable as accomplices under Article 18 of the Revised Penal Code because it was not proven that they knew of Marceliano's criminal design at the time they inflicted blows upon the deceased. The essential condition for complicity requires knowledge of the criminal intent and efficacious cooperation. On whether the accused-appellants are guilty of slight physical injuries: The Court concluded that the crime committed by the appellants was slight physical injuries, punishable under paragraph 2 of Article 266 of the Revised Penal Code, as there was no proof regarding the period of incapacity for labor or the required medical attendance. This offense was aggravated by the circumstance of abuse of superior strength, as they took advantage of their numbers and the victim's weakened state. The trial court correctly disregarded evident premeditation.
Main Doctrine
Appellants, who inflicted contusions upon the victim but did not participate in the fatal stabbing, cannot be held liable for murder or homicide. Their liability is limited to slight physical injuries, aggravated by superior strength, as they did not conspire with nor were they aware of the principal culprit's criminal intent.