GR L 30801; (March, 1974) (Digest)
G.R. No. L-30801 March 27, 1974
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DOMINGO URAL, accused-appellant.
FACTS
Accused-appellant Domingo Ural, a policeman, was convicted of murder for the death of detention prisoner Felix Napola. The prosecution’s case primarily rested on the eyewitness account of Brigido Alberto. Alberto testified that on the night of July 31, 1966, while at the Buug municipal building, he saw Ural inside the jail boxing Napola until he collapsed. Ural then stepped on the victim, left, returned with a bottle, poured its contents on Napola, and ignited it with a match. Napola screamed in agony and later died on August 25, 1966, from complications of second-degree burns. Alberto fled after Ural warned him to keep quiet. The defense presented a contrary version, claiming Ural was on guard duty, heard screams, and found Napola’s shirt on fire, which he and others extinguished. The defense also attacked Alberto’s credibility, noting he was a convicted murderer and was not originally listed as a prosecution witness.
ISSUE
Whether the prosecution evidence, particularly the testimony of Brigido Alberto, is sufficient to prove the guilt of Domingo Ural for murder beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction. The core issue was one of credibility, and the trial court’s assessment, having observed the witnesses’ demeanor, was accorded great weight. The Court found no reason to overturn the trial judge’s finding that Alberto was a credible witness. The fact that Alberto was a convicted prisoner and an unlisted witness did not automatically discredit his testimony, especially given the peculiar circumstances where the accused was a policeman and no proper police investigation was conducted. The defense’s version was deemed incompatible with the evidence and the natural course of events. On the legal qualification of the crime, the Court applied Article 4 of the Revised Penal Code on the doctrine of “proximate cause.” Ural intended to inflict harm by burning Napola. The victim’s subsequent death from infection and toxemia, while not the exact intended consequence, was the direct and natural result of the burns inflicted. The act of burning, done with evident malice, constituted murder. The penalty of reclusion perpetua and the indemnity were thus upheld.