People v. Cornel
REITERATIONFacts
The Antecedents: On June 8, 1945, at about 6 o'clock in the afternoon, in the Barrio of San Miguel, Municipality of Tabaco, Province of Albay, the appellant Gerardo Cornel allegedly assaulted Fabian Burac with a bolo as the latter was descending the stairs of his house. After Fabian Burac fell, wounded in the forehead, the appellant threw a stone which hit Fabian's right clavicle, and then fled. Fabian Burac died several days later, on June 15, 1945, from tetanus secondary to the infected wound. Procedural History: The defendant was prosecuted for physical injuries even before Fabian's death. The Court of First Instance of Albay rendered a judgment sentencing the defendant for the crime of homicide. The Petition: The defendant appealed the judgment, raising issues regarding the sufficiency of evidence for his identity, the nature of the wound, the cause of death, and his defense of alibi.
Issue(s)
Whether the evidence presented by the prosecution was sufficient to establish the identity of the appellant as the assailant. Whether the wound on the victim's forehead was produced by a bolo or by an irregular and hard object. Whether the death of Fabian Burac was sufficiently established and if it was a direct consequence of the appellant's unlawful act. Whether the appellant's defense of alibi was tenable.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance of Albay, sentencing the defendant for the crime of homicide. The Court found sufficient proof regarding the appellant's identity and held him responsible for the natural consequences of his unlawful act.
Ratio Decidendi
On the identity of the assailant: The Court held that the positive testimony of Trinidad Coral, an eyewitness who personally saw the appellant assault the deceased with a bolo and then throw a stone, was sufficient to establish the appellant's identity. Trinidad Coral knew the appellant well, and her testimony was given full credit by the trial court, which had the advantage of observing her demeanor. Furthermore, the testimony of another witness, Caspara Bendicio, wherein the victim identified the appellant as the one who boloed him shortly after the incident, was admitted under the rule of res gestae. The Court noted that the appellant had previously been prosecuted for physical injuries even before the victim's death, further supporting his involvement. On the nature of the wound: While acknowledging that the appellant's contention regarding the wound being produced by a stone might be tenable in forensic medicine, the Court found it to be conjectural. This contention could not be accepted where, as in this case, a criminal assault was proven through an eyewitness. The eyewitness account of the assault with a bolo was deemed more credible than the speculative medical interpretation of the wound's origin. On the cause of death: The Court found no doubt that Fabian Burac died of tetanus secondary to the infected wound, as certified by Dr. Mariano Cruel, who treated the victim. Dr. Cruel observed the manifestations of tetanus, including slight lock-jaw, when the victim last reported for treatment and prescribed anti-tetanic serum. The appellant's surmise that the victim might have died of another disease was rejected, as it could not prevail against the conclusion of the doctor who treated the wound and observed the symptoms. The Court reiterated the principle that the appellant must be held responsible for the natural consequences of his unlawful act, citing People vs. Borbano. On the defense of alibi: The Court considered the defense of alibi to be worth inquiring into only if the eyewitness testimony was not credible. However, since Trinidad Coral was found to be a truthful eyewitness to the appellant's criminal attack, the alibi defense, which placed the appellant in Tabaco, Albay, between 5 p.m. of June 8, 1945, and the morning of June 9, 1945, was not given weight. The Court also noted that the motive for the offense was supplied by the circumstance that the victim had previously arrested and threatened the appellant during the Japanese occupation.
Main Doctrine
The positive testimony of an eyewitness, who knew the appellant well, is sufficient to establish the identity of the assailant, even if the attack occurred at dusk, especially when corroborated by the victim's dying declaration under the res gestae rule. The accused is responsible for the natural consequences of his unlawful act, including death resulting from complications like tetanus, even if the specific treatment was unavailable.