G.R. No. 63118 September 1, 1989
JOSE RODRIGUEZ and ROSALINO BALANTA, petitioners, vs. SANDIGANBAYAN and the PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioners Jose Rodriguez and Rosalino Balanta, police officers of Sto. Domingo, Albay, were convicted by the Sandiganbayan of homicide for the death of Jose Bandagoza. The prosecution’s eyewitness, Francisco Anonuevo, testified that on the evening of February 23, 1980, he saw the petitioners, in uniform, repeatedly kick Bandagoza while walking him towards the municipal hall. Upon reaching the building, Anonuevo witnessed through a window the petitioners taking turns striking Bandagoza with their fists in the face, head, and abdomen for about five minutes until Bandagoza fell unconscious. Bandagoza was then detained overnight and released the next morning to his sister, complaining of severe pains and stating he had been beaten by policemen.
Bandagoza’s condition deteriorated, and he died on March 5, 1980. The initial death certificate issued by Dr. Orlando Braga listed the cause as “meningitis.” However, upon the sister’s request, the body was exhumed and autopsied by NBI medico-legal officer Dr. Rolando Oba, who found hematoma and severe intracranial hemorrhage caused by traumatic force like fist blows or kicks, concluding the cause of death as “hemorrhage, severe, intracranial, traumatic.” The petitioners denied the accusations, claiming they merely assisted a drunk Bandagoza to the jail, where he accidentally fell.

ISSUE

The core issue is whether the Sandiganbayan erred in convicting the petitioners of homicide based on the evidence presented, particularly in reconciling the initial medical finding of meningitis with the autopsy report of traumatic hemorrhage and in assessing the credibility of the eyewitness.

RULING

The Supreme Court affirmed the conviction. The ruling hinges on the principle that factual findings of the Sandiganbayan, when supported by substantial evidence, are conclusive on the Supreme Court in a petition for review under Rule 45. The Court found no reason to deviate from this rule. The Sandiganbayan correctly gave greater weight to the detailed and categorical eyewitness account of Francisco Anonuevo over the petitioners’ denial. The Court dismissed the alleged motive of Anonuevo, noting that his relationship to the victim and prior admonishment by the petitioners did not automatically impair his credibility, especially as his testimony was clear and consistent.
On the crucial medical evidence, the Court upheld the Sandiganbayan’s reliance on the autopsy report of Dr. Oba over the initial death certificate. Dr. Oba’s findings, based on a direct examination of the exhumed body, conclusively established that the traumatic injuries inflicted were the direct cause of death. The Court logically reconciled the medical opinions by noting that the traumatic intracranial hemorrhage could have induced or complicated a meningeal condition, making the initial diagnosis of meningitis not inconsistent with the finding that the hemorrhage was the proximate cause of death. The petitioners’ infliction of violent blows was the direct and efficient cause that set in motion the chain of events leading to death, satisfying the element of causality for homicide. The indemnity was increased to P30,000.00.