GR 138666; (March, 2001) (Digest)
G.R. No. 138666 March 1, 2001
ISABELO LORENZANA, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.
FACTS
Petitioner Isabelo Lorenzana, a member of a police towing unit, was charged with Homicide for the death of Napoleon Nazareth, Sr. The prosecution alleged that on November 24, 1992, in Manila, after the victim presented overnight parking permits for his jeepneys, petitioner struck him on the head with a gun. Eyewitnesses Reynaldo Santos and Allan Transmonte, both pedicab drivers, testified they saw petitioner pistol-whip the victim, who then fell, trembled, and was later pronounced dead at the hospital. The NBI autopsy report concluded the cause of death was traumatic head injuries.
The defense presented a contrary version, claiming the victim, who was angry and trembling, suddenly fell after their brief encounter. Petitioner insisted the victim had a pre-existing heart condition and suggested the fatal fall was due to a heart attack, not the alleged gun-whipping. He challenged the credibility of the prosecution witnesses, claiming Santos was a “planted” witness.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s conviction, which relied on the prosecution witnesses’ testimonies and the autopsy report, despite the petitioner’s claim that the victim’s death was caused by a heart ailment.
RULING
The Supreme Court denied the petition and affirmed the conviction. The Court emphasized that in a Petition for Review under Rule 45, only questions of law may be raised. Factual findings of the trial court, especially when affirmed by the appellate court, are generally conclusive and binding. The defense failed to present any convincing evidence to overturn these findings.
The legal logic rests on the principle that the cause of death in criminal cases must be established by competent proof. Here, the prosecution evidence—the consistent and detailed eyewitness accounts corroborated by the medical finding of traumatic head injuries—sufficiently proved that petitioner’s act caused the victim’s death. The Court found no ill motive for the witnesses to falsely testify. Petitioner’s alternative theory of a heart attack was speculative and unsupported by the autopsy report or any medical testimony. Without proof of a supervening cause that broke the chain of causation, the traumatic injury inflicted by petitioner remained the proximate cause of death. Thus, the factual conclusions of the lower courts, being supported by evidence, were upheld.