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    (GROUP 3) Garcia vs. People Case Digest

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    1. The petitioner and others had a drinking spree near the victim Manuel Chy's home, angering the petitioner when Chy asked them to be quiet. 2. A few days later, the petitioner struck Chy in the face and hit him with a beer bottle when Chy approached their group. Chy later died of a myocardial infarction at home. 3. The autopsy revealed Chy had a previous heart condition and the emotional stress from the beating aggravated his health, directly leading to his death. Therefore, the petitioner was criminally liable for Chy's death despite not intending to cause it.

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    (GROUP 3) Garcia vs. People Case Digest

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    174 views2 pages
    1. The petitioner and others had a drinking spree near the victim Manuel Chy's home, angering the petitioner when Chy asked them to be quiet. 2. A few days later, the petitioner struck Chy in the face and hit him with a beer bottle when Chy approached their group. Chy later died of a myocardial infarction at home. 3. The autopsy revealed Chy had a previous heart condition and the emotional stress from the beating aggravated his health, directly leading to his death. Therefore, the petitioner was criminally liable for Chy's death despite not intending to cause it.

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    1. The petitioner and others had a drinking spree near the victim Manuel Chy's home, angering the petitioner when Chy asked them to be quiet. 2. A few days later, the petitioner struck Chy in the face and hit him with a beer bottle when Chy approached their group. Chy later died of a myocardial infarction at home. 3. The autopsy revealed Chy had a previous heart condition and the emotional stress from the beating aggravated his health, directly leading to his death. Therefore, the petitioner was criminally liable for Chy's death despite not intending to cause it.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    174 views2 pages

    (GROUP 3) Garcia vs. People Case Digest

    Uploaded by

    Von
    1. The petitioner and others had a drinking spree near the victim Manuel Chy's home, angering the petitioner when Chy asked them to be quiet. 2. A few days later, the petitioner struck Chy in the face and hit him with a beer bottle when Chy approached their group. Chy later died of a myocardial infarction at home. 3. The autopsy revealed Chy had a previous heart condition and the emotional stress from the beating aggravated his health, directly leading to his death. Therefore, the petitioner was criminally liable for Chy's death despite not intending to cause it.

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    Case Digest

    AMADO ALVARADO GARCIA, petitioner v. PEOPLE OF THE PHILIPPINES,


    respondent.
    [G.R. NO. 171951 : August 28, 2009]

    Facts: On September 26, 1999, petitioner, Fidel Foz J.r., and Armand Foz J.r had a
    drinking spree at the apartment unit of Bogie Tacuboy, which was adjacent to the
    house of Manuel K. Chy. Chy appealed to the group to quiet down, but it was only
    when Chy appealed for a second time that the group acceded. This left the petitioner
    irate, he was heard to have said in Ilocano vernacular, “Manny is arrogant, I will lay a
    hand on him”.

    On September 28, 1999, the group met again not far from Chy’s apartment. Maya
    Mabbun advised the group to stop singing lest they be told off again. This further
    infuriated the petitioner, who remarked in Ilocano vernacular, “This Manny is really
    arrogant, I will not let him live long”.

    On September 29,1999, the group passed by the store of Chy’s sister and decided to
    have some drinks. At this juncture, petitioner ordered the victim’s sister to call Chy,
    who was incidentally coming out of his house. Upon being summoned, Chy
    approached the petitioner who suddenly boxed him in the face. Petitioner reached for
    a bottle of beer, and with it, struck the lower portion of Chy’s head. When Chy found
    an opportunity to escape, he ran towards the house and phoned his wife to call the
    police. Chy told his wife about the beating and complained of difficulty in breathing.
    Upon reaching Chy’s house, the policeman knocked five times but nobody answered.
    Josephina, Chy’s wife, arrived minutes later, unlocked the door and found Chy lying
    unconscious on the kitchen floor, salivating. He was pronounced dead on arrival at the
    hospital. The autopsy confirmed that Chy died of myocardial infarction.

    The Regional Trial Court of Appari, Cagayan (Branch 9), found the petitioner guilty
    beyond reasonable doubt of homicide. However, Chy raised the defense that he
    cannot be tried for homicide, because the death of Manuel Chy was due to myocardial
    infarction.

    Issue: Whether or not Amado Garcia is criminally liable for the death of Manuel Chy.
    Ruling: Yes the petitioner is criminally liable for the death of Manuel Chy.

    The Autopsy Report on the body of Manuel Chy disclosed the following injuries: Heart,
    with abundant fat adherent on its epicardial surface. Cut sections show a reddish
    brown myocardium with an area of hyperemia on the whole posterior wall, the lower
    portion of the anterior wall and the inferior portion of the septum. Coronary arteries,
    gritty, with the caliber of the lumen reduced by approximately thirty (30%) percent.
    Histopathological findings show mild fibrosis of the myocardium.

    The petitioner admitted inflicting injuries on the deceased, albeit, limited his liability to
    slight physical injuries. He argues that the superficial wounds sustained by Chy did not
    cause his death. Quite the opposite, however, a conscientious analysis of the records
    would acquaint us with the causal connection between the death of the victim and the
    mauling that preceded it. The Autopsy Report bears out that Chy has a mild fibrosis of
    the myocardium caused by a previous heart attack. Said fibrosis or formation of fibrous
    tissue or scar tissue rendered the middle and thickest layer of the victim's heart less
    elastic and vulnerable to coronary occlusion from sudden emotion. It can be
    reasonably inferred from the foregoing statements that the emotional strain from the
    beating aggravated Chy's delicate constitution and led to his death. The inevitable
    conclusion then surfaces that the myocardial infarction suffered by the victim was the
    direct, natural and logical consequence of the felony that petitioner had intended to
    commit.

    Article 4(1) of the Revised Penal Code states that criminal liability shall be incurred
    "By any person committing a felony (delito) although the wrongful act done be different
    from that which he intended." The essential requisites for the application of this
    provision are: (a) the intended act is felonious; (b) the resulting act is likewise a felony;
    and (c) the unintended, albeit graver wrong was primarily caused by the actor's
    wrongful acts. In this case, petitioner was committing a felony when he boxed the
    victim and hit him with a bottle. Hence, the fact that Chy was previously afflicted with
    a heart ailment does not alter petitioner's liability for his death.

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