GR 73747; (November, 1991) (Digest)
G.R. No. 73747 November 21, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DENNIS SONG and ELMO LABRIAGA, accused, ELMO LABRIAGA, accused-appellant.
FACTS
On the evening of August 29, 1982, during a dance in Barangay Resurreccion, San Fernando, Masbate, accused-appellant Elmo Labriaga was seen handing a machete to his co-accused, Dennis Song, who was intoxicated. The two then entered the dance hall. Shortly thereafter, Labriaga, without warning, held the victim, Percival Alcovendas, while Song approached and stabbed him in the back with the machete. Both assailants fled. The wounded victim was brought to a hospital where he died five days later from complications diagnosed as cardiac arrest and acute peritonitis secondary to the stab wound. An information for murder was filed against both accused. Song remained at large, and trial proceeded against Labriaga, who was convicted by the Regional Trial Court and sentenced to reclusion perpetua.
ISSUE
The core issues are: (1) whether the stab wound inflicted was the proximate cause of the victim’s death, and (2) whether appellant’s guilt was proven beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. On the first issue, the Court held that the stab wound was the proximate cause of death. The medical diagnosis established a direct causal link between the inflicted wound and the fatal peritonitis and cardiac arrest. Applying the doctrine of proximate cause, the Court ruled that an assailant is responsible for all natural consequences of his felonious act, including death resulting from complications or even from medical treatment, provided the chain of causation is not broken by an efficient intervening cause. The victim’s death was a direct and natural result of the stab wound.
On the second issue, the Court found appellant’s guilt proven beyond reasonable doubt through the credible, consistent, and corroborated eyewitness testimonies of Patrocino Albano and Dominica Alcovendas. They clearly narrated how Labriaga held the victim to facilitate Song’s sudden and fatal attack. Their testimonies were deemed reliable, given their clear view under well-lighted conditions and the absence of proven ill motive to falsely testify. Appellant’s defense of denial and alibi was weak and uncorroborated. The Court also found conspiracy and treachery (alevosia). Labriaga’s act of providing the weapon and holding the victim, combined with Song’s sudden attack from behind, ensured the victim had no opportunity to defend himself, qualifying the killing as murder. The judgment was affirmed with modification, increasing the civil indemnity.