People v. Abiog
REITERATIONFacts
The Antecedents: The deceased, Anacleto Cudiamat (C), approached Vicente Abiog (V) and Luis Abiog (L) while they were cleaning a caua and made a remark. V, feeling indignant, challenged C to a fight, went to his house to procure a revolver, and returned to the field. During this time, V's brother, Marcelino Abiog, attempted to disarm V and was killed, likely accidentally. V then loaded the revolver and shot C in the stomach. L then intervened when C's wife attempted to succor her husband, attacking C with a bolo. C's nephew, Urbano Banastas, was also wounded. Procedural History: The Court of First Instance of Batangas found both defendants guilty of homicide and sentenced them to eight years of presidio mayor, with accessory penalties, and to pay P1,000 jointly and severally to the heirs of the deceased. The Petition: The defendants appealed the judgment of the trial court.
Issue(s)
Whether the defendants, acting independently, can be held jointly liable for homicide when it is uncertain which of the two wounds inflicted was the mortal one. Whether the claim of self-defense by Vicente Abiog is tenable. Whether Luis Abiog is criminally responsible for the death of Anacleto Cudiamat.
Ruling
The Supreme Court modified the penalty imposed by the lower court. Both defendants were sentenced to twelve years and one day of reclusion temporal, with accessory penalties, and to jointly and severally pay P1,000 to the heirs of the deceased.
Ratio Decidendi
On the issue of independent acts and joint liability for homicide: The Court held that in the absence of conspiracy or a concerted plan, criminal liability for separate acts committed against the same person is individual, not collective. Each culprit is responsible only for the acts committed by himself. In this case, both Vicente Abiog and Luis Abiog inflicted wounds upon the deceased, either of which could have caused death. The Court found that both wounds operated to cause death, and death was imputable to each defendant. The burden rested upon each defendant to show that the wound inflicted by him did not cause death, a burden neither met. Therefore, both were held liable for homicide. On the claim of self-defense by Vicente Abiog: The Court found the claim of self-defense incontestable, stating that Anacleto Cudiamat made no attack that warranted Vicente Abiog in procuring a revolver and shooting him, especially after the interference of his brother. The act of procuring a weapon and shooting the victim negated any valid claim of self-defense. On the criminal responsibility of Luis Abiog: The Court determined that Luis Abiog was also criminally responsible for homicide. Although he acted independently of his brother, his bolo wound was also a mortal wound that contributed to the death of Anacleto Cudiamat. The Court reasoned that since both wounds contributed to the death, and neither defendant could prove their wound was not the cause of death, both were liable. The Court applied the principle that if a wound inflicted by a defendant contributes to the death, even if other independent causes also contributed, the causal relation is established.
Main Doctrine
In the absence of conspiracy or concerted plan, where multiple individuals acting independently inflict wounds upon a single victim, each individual is criminally liable only for the consequences of their own acts. The burden rests upon each defendant to prove that their wound did not cause or contribute to the death of the victim.