G.R. No. L-4082
THE UNITED STATES, plaintiff-appellee, vs. MANUEL LORENZANA, ET AL., defendants-appellants.
November 18, 1908

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FACTS:

On the night of November 26, 1906, Honesto Mina, while part of a serenading party in Tagudin, Ilocos Sur, suddenly received severe blows to his head, crushing his skull. He fell senseless and died the following morning. Manuel Lorenzana and Mariano Lorenzana were accused of inflicting the fatal wounds with clubs. The trial court found both brothers guilty of homicide and sentenced them to twelve years and one day of reclusion temporal each.

The prosecution presented several witnesses. Simon Mina testified that he found the Lorenzana brothers in a hostile attitude near the deceased, and that Mariano Lorenzana made a hostile remark. The deceased, before dying, identified “los dos hermanos” (the two brothers) as his assailants. Mariano Sarmiento claimed to have seen both accused strike the deceased. Juan Manzano testified seeing the accused near the fallen victim and heard the deceased identify them. Eulalio Valdez, in his initial testimony, stated he saw both strike the deceased, but on cross-examination, he was less certain about Manuel, observing him rush towards his brother when the victim fell. The defense challenged the credibility of Sarmiento and Manzano due to their enmity and a prior perjury conviction, respectively. The defense also questioned the admission of a medical certificate of autopsy without the testimony of the medical officer.

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ISSUE:

1. Was there sufficient credible evidence to convict both Manuel Lorenzana and Mariano Lorenzana of homicide beyond a reasonable doubt?
2. Was the medical certificate of the autopsy properly admitted as evidence?

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RULING:

1. Yes, for Mariano Lorenzana; No, for Manuel Lorenzana.
The Supreme Court found the uncorroborated testimonies of Mariano Sarmiento and Juan Manzano to be of little value due to their established prejudice and prior perjury conviction, respectively. However, the Court held that the statements of Simon Mina and Eulalio Valdez, coupled with the ante-mortem statement of the deceased identifying “the two brothers,” were sufficient to establish the guilt of Mariano Lorenzana beyond a reasonable doubt.

For Manuel Lorenzana, the Court found reasonable doubt. Eulalio Valdez’s cross-examination indicated that Manuel might have merely rushed to his brother’s aid rather than directly participating in the fatal blow. The ante-mortem statement, while naming both, did not conclusively prove Manuel’s direct involvement in the assault itself, as the victim might have perceived his presence as hostile assistance. Thus, there was insufficient reliable evidence to convict Manuel.

2. No, but it was an error without prejudice.
The Court ruled that the medical certificate of the autopsy was erroneously admitted. While official documents can be certified, their admission does not waive the necessity of proving their contents in court when the truth of the facts is questioned, nor does it override the accused’s right to confront and cross-examine witnesses. However, the error was “without prejudice” because the fact that the deceased died from the wounds inflicted was established beyond reasonable doubt by other, properly admitted testimony.

The Supreme Court reversed the trial court’s judgment.
Mariano Lorenzana was found guilty of homicide. Given that he appeared to be less than eighteen years of age at the time of the crime (an extenuating circumstance), the penalty was reduced to eight years and one day of prision mayor, along with accessory penalties, a civil indemnity of P1,000 to the heirs, and half the costs.
Manuel Lorenzana was acquitted due to reasonable doubt and ordered released, with his share of costs de oficio.