G.R. No. L-29090. April 29, 1974.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTOLIN CARDENAS, ANTONIO CARDENAS and DELFIN CARDENAS, defendants. ANTOLIN CARDENAS, defendant-appellant.

FACTS

On the evening of January 13, 1964, in Barrio Cervantes, Catarman, Samar, Adolfo Mariño entered the store of Victorio Teopinto to buy liquor. After being told there was none, Mariño insisted Teopinto accompany him to buy some elsewhere, leading him out of the store. Shortly after, Teopinto was heard calling for help. Eyewitnesses, including Teopinto’s widow Adelina and Igmedio Ladeño, saw appellant Antolin Cardenas, together with several armed companions, attacking and slashing Teopinto with bolos on the street. The area was illuminated by nearby Petromax lamps. The prosecution established that four days prior, Teopinto had informed his wife he would testify against appellant in a criminal case for shooting another individual.
The victim sustained multiple wounds. The autopsy report indicated an old head injury (Wound No. 8) from a previous November 1963 incident and new injuries from the January attack, including a crucial new wound on the forehead (Wound No. 7). Medical testimony clarified that while the old injury was healing, the new trauma from Wound No. 7 caused a fresh thrombus that directly resulted in Teopinto’s death. The trial court convicted appellant of murder qualified by treachery and evident premeditation, sentencing him to reclusion perpetua.

ISSUE

Whether the Court of First Instance erred in convicting appellant Antolin Cardenas of murder.

RULING

The Supreme Court affirmed the conviction for murder but modified the civil indemnity. The legal logic centered on establishing the appellant’s criminal liability for the killing, which was qualified by treachery, and addressing the cause of death and the aggravating circumstance of premeditation. The Court found conspiracy was deducible from the coordinated acts of luring the victim out and the sudden, concerted attack. The attack was sudden and unexpected, ensuring the victim had no chance to defend himself, thereby qualifying the killing with treachery.
On the cause of death, the Court held appellant liable even though the victim had a prior head injury. Medical evidence established that the new wound inflicted by appellant’s group produced a fatal thrombus. An offender is responsible for all natural and logical consequences of their unlawful acts. Thus, the infliction of the new wounds, which directly caused death, made appellant criminally liable. However, the Court found evident premeditation was not sufficiently proven, as the prosecution failed to establish the required elements: the time the offender decided to commit the crime, an act showing persistence in that decision, and a sufficient lapse of time for reflection. Finally, following prevailing jurisprudence, the Court increased the civil indemnity to the heirs of the deceased from P6,000 to P12,000. The modified judgment affirmed the penalty of reclusion perpetua with the increased indemnity.