Seguritan v.

People
G.R. No. 172896 April 19, 2010
Lessons Applicable: intent
FACTS:

November 25,1995: Roo Seguritan y Jara alias Ranio was having a drinking
session with his uncles Lucrecio Seguritan (51 year old farmer), Melchor Panis
and Baltazar Panis, in the house of Manuel dela Cruz. Ranio was seated beside
Lucrecio as he claimed that Lucrecios carabao entered his farm and destroyed
his crops which bun the heated argument. As Lucrecio was about to stand up,
he punched him twice hitting him in the right and left temple causing him to fall
face-up to the ground and hit a hollow block which was being used as an
improvised stove causing him to fall face-up to the ground and hit a hollow block
which was being used as an improvised stove. Lucrecio rode a tricycle
home. His wife noticed blood on his forehead so he explained that he was
stoned.
November 25,1995 9pm: Lucrecios wife and daughter noticed that his
complexion has darkened and foamy substance was coming out of his mouth as
he slept. They tried to revive Lucrecio but failed.
December 4, 1995: Lucrecios wife learned of the incident and requested the
assistance of the NBI. NBI Medico-Legal Officer Dr. Vertido concluded that
Lucrecios cause of death was traumatic head injury
October 1, 1996: He was charged with Homicide
Ranio presented Joel Cabebe, the Assistant Registration Officer of Gonzaga,
Cagayan, and Dr. Corazon Flor, the Municipal Health Officer of Sta. Teresita,
Cagayan, to prove that Lucrecio died of a heart attack
RTC: homicide
CA: Affirmed
Ranio argued that he should be liable only for reckless imprudence resulting in
homicide due to the absence of intent to kill Lucrecio

ISSUE: W/N Ranio is guilty of homicide even if there is no intent

HELD: YES. petition is DENIED. AFFIRMED penalty of six years and one day of prision
mayor as minimum, to 12 years and one day of reclusion temporal as maximum with
MODIFICATION that petitioner is further ordered to pay P25,000.00 as temperate
damages in lieu of actual damages, and P50,000.00 as civil indemnity

When death resulted, even if there was no intent to kill, the crime is homicide, not
just physical injuries, since with respect to crimes of personal violence, the penal
law looks particularly to the material results following the unlawful act and holds
the aggressor responsible for all the consequences thereof.
Article 4 of the Revised Penal Code provides
1. By any person committing a felony (delito) although the wrongful act
done be different from that which he intended.
Unlawful act - punching Lucrecio
He who is the cause of the cause is the cause of the evil caused