People v. Reloj
REITERATIONFacts
The Antecedents: On July 7, 1963, at approximately 3:00 p.m., the appellant, Pablo Reloj, stabbed the victim, Justiniano Isagan Sr., with an ice pick wrapped in paper, outside the cockpit in Libtong, Kalibo, Aklan. The victim was brought to the Aklan Provincial Hospital, where he underwent surgery. Although he appeared to be recovering, he developed a paralytic ileum five days later and subsequently died. The prosecution presented testimonies from Justiniano Isagan Jr. (son of the deceased), Hermie Zante, and an ante-mortem declaration from the deceased. These witnesses testified that the appellant approached the victim from behind, placed his hand on the victim's shoulder, and stabbed him in the abdomen. The appellant then allegedly threatened Justiniano Jr. and was later arrested by a policeman after voluntarily surrendering at a nearby store. The prosecution also presented testimonies from Rogelio Ibardolaza and Angel de la Cruz, who claimed the appellant had expressed an intent to kill Justiniano Sr. earlier that day. The appellant, however, claimed he was collecting a P10 bet from the victim when the latter became enraged and attacked him, leading him to use the ice pick in self-defense. He also claimed to have voluntarily surrendered. Procedural History: The Court of First Instance of Aklan convicted the appellant of murder, sentencing him to life imprisonment, indemnifying the heirs of the victim, and imposing accessory penalties. The appellant appealed this decision. The Petition: The appellant maintained that the lower court erred in giving credence to prosecution witnesses, not finding lack of intent to kill, holding him responsible for the death, qualifying the crime as murder by treachery, not considering incomplete self-defense, lack of intent to commit so grave a wrong, and voluntary surrender, and in imposing the penalty of life imprisonment.
Issue(s)
Whether the appellant is responsible for the death of Justiniano Isagan Sr., considering the subsequent medical complications. Whether the crime committed is murder qualified by treachery. Whether the appellant acted in incomplete self-defense. Whether there was a lack of intent to commit so grave a wrong. Whether voluntary surrender to the authorities should be considered a mitigating circumstance. Whether the penalty imposed by the lower court is correct.
Ruling
The Supreme Court affirmed the conviction for murder but modified the penalty. The Court ruled that the appellant is responsible for the death of the victim, the crime was qualified by treachery, and the defenses of incomplete self-defense and lack of intent to commit so grave a wrong were unmeritorious. The Court recognized voluntary surrender as a mitigating circumstance, leading to the imposition of the penalty in its minimum period.
Ratio Decidendi
On the appellant's responsibility for the death of Justiniano Isagan Sr.: The Court held that the appellant is responsible for the death, as the injury he inflicted with a deadly weapon put the victim's life in jeopardy. The subsequent development of paralytic ileum, which necessitated a surgical operation due to the abdominal injury, was considered a natural consequence of the felonious act. Citing People v. Quianzon, the Court reiterated the principle that if a person inflicts a wound with a deadly weapon in a manner that puts life in jeopardy, and death follows as a consequence of this act, it does not alter the nature or diminish the criminality of the act, even if other causes cooperated in producing the fatal result. The Court emphasized that a different doctrine would allow criminals to escape conviction due to the uncertainties of medical treatment. On the qualification of the crime as murder by treachery: The Court found that the lower court did not err in qualifying the offense as murder by treachery. The evidence showed that the appellant attacked Justiniano Sr. suddenly from behind while the victim was standing under a mango tree, with no opportunity to defend himself. This mode of attack, which insured the execution of the crime without risk to the aggressor arising from the defense which the offended party might make, squarely fits the definition of treachery. On the defense of incomplete self-defense: The Court found the invocation of incomplete self-defense to be devoid of merit. This defense was based solely on the appellant's uncorroborated testimony, which the Court found to be unworthy of credence. Furthermore, the appellant's version of events was inconsistent with the treachery with which he attacked Justiniano Sr., as established by the prosecution witnesses. On the alleged lack of intent to commit so grave a wrong: The Court found no merit in the argument that there was a lack of intent to commit so grave a wrong. The appellant's use of a deadly ice pick, the stabbing of a vital part of the victim's body (the abdomen), and his prior statements expressing an intent to "kill" Justiniano Sr. left no room for doubt about his intent to slay the victim. On voluntary surrender as a mitigating circumstance: The Court found that the appellant had voluntarily surrendered to the authorities. This fact was established and was considered a mitigating circumstance in his favor. The Court noted that the appellant went to a nearby store and waited for a policeman to arrest him. On the penalty imposed: Given that voluntary surrender was a mitigating circumstance and there were no aggravating circumstances to offset it, the Court ruled that the penalty prescribed by law for murder should be imposed in its minimum period. Consequently, the appellant should be sentenced to an indeterminate penalty ranging from 10 years and 1 day of prision mayor to 17 years, 4 months and 1 day of reclusion temporal, with the corresponding accessory penalties and costs.
Main Doctrine
The proximate cause of death is the unlawful act of the accused, even if subsequent medical intervention, necessitated by the injury inflicted, contributes to the fatal result. Voluntary surrender is a mitigating circumstance that warrants the imposition of the penalty in its minimum period.