CASE DIGEST : LAGAO VS PEOPLE OF THE PHILIPPINES GE 217721 GAERLAN

 

[ G.R. No. 217721. September 15, 2021 ]

BENJIE LAGAO Y GARCIA, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

D E C I S I O N

FACTS : In this case, petitioner Benjie Lagao y Garcia was charged with homicide for allegedly attacking Anthony Sumad-ong Nerida on February 20, 2008, resulting in injuries that caused the victim’s death two days later. During trial, prosecution witnesses—De Guzman, Cruz, and Nerida Sr., the victim’s father—testified that the victim identified the petitioner as the assailant, describing that he was struck on the nose and the back of the head with a hard object. De Guzman and Cruz observed the victim’s bleeding wounds but noted he did not seek medical attention. The defense denied the petitioner’s involvement, and Dr. Bernardo Parado, Municipal Health Officer, conducted an autopsy, reporting that the victim had a superficial laceration under the skin but also clarified that the ultimate cause of death was “cardio-respiratory arrest secondary to hypovolemic shock secondary to intracranial hemorrhage secondary to blunt force injury” in the occipital area. The autopsy and testimonies became key evidence in establishing the link between the petitioner and the fatal injury. The RTC found Benjie Lagao y Garcia guilty of homicide, sentencing him to 8 years and 1 day to 12 years and 1 day of imprisonment, ordering him to pay actual damages of ₱18,600, moral damages of ₱50,000, death indemnity of ₱50,000, and costs. The RTC relied on the victim’s declarations to witnesses De Guzman and Cruz identifying the petitioner as the attacker, giving full credence to these testimonies since no ill motive was shown. On appeal, the CA affirmed the conviction, ruling that the witnesses’ accounts were not hearsay because they only proved that the victim made the statements, not the truth of the statements themselves, and considered them as part of res gestae. The CA held that these testimonies, along with Dr. Parado’s findings, outweighed the petitioner’s denial, establishing guilt beyond reasonable doubt. The petitioner’s motion for reconsideration was denied on March 20, 2015.

ISSUE : WON the CA erred in affirming the judgement of the RTC 

HELD : The Court found merit in the petition for review, noting that the CA and RTC erred in affirming the conviction. The ruling emphasized that the prosecution failed to prove the petitioner’s guilt beyond reasonable doubt, particularly due to conflicting evidence regarding the cause of the victim’s death: the death certificate cited natural causes, while the autopsy suggested death from blunt force trauma. Applying the equipoise rule, any reasonable doubt regarding the cause of death favored acquittal. Furthermore, the Court held that the victim’s statements identifying the petitioner were inadmissible: they did not qualify as a dying declaration because the victim was not under the consciousness of impending death, and they were not part of res gestae because there was a significant lapse of time and intervening events that allowed reflection, negating spontaneity. Without direct eyewitnesses or admissible declarations, the prosecution failed to establish the petitioner’s identity as the assailant. Consequently, the Court granted the petition, reversed and set aside the RTC and CA decisions, and acquitted Benjie Lagao y Garcia of homicide.