GR L 54562; (August, 1987) (Digest)
G.R. No. L-54562 August 6, 1987
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANILO PUNZALAN, VGET ISON and GUILBERT CUISON, defendants-appellants.
FACTS
This is an automatic review of a death penalty conviction for Murder. The prosecution’s evidence established that on June 11, 1978, appellants Danilo Punzalan, Vget Ison, and Guilbert Cuison, along with others including Ramon Jumawan (at large), were drinking at a restaurant in Parañaque. Cpl. Maximo de los Santos, a policeman in civilian clothes, approached their table and identified himself, asking if anyone had a gun. Wally Punzalan, Danilo’s brother, drew a .45 caliber pistol. The policeman immediately drew his service revolver and shot Wally twice before Wally could fire. Jumawan then struck the policeman with a chair, causing him to fall.
The appellants Punzalan and Cuison joined in hitting the fallen policeman with chairs, and Ison hit him with a beer bottle. While the victim was prostrate and helpless, Jumawan seized the policeman’s gun and shot him four times, causing his death. The trial court found all three appellants guilty as principals for the murder, qualified by treachery and abuse of superior strength, and sentenced them to death.
ISSUE
Whether the appellants are guilty of the crime of Murder for the death of Cpl. Maximo de los Santos.
RULING
No. The Supreme Court acquitted the appellants. The legal logic centered on the sequence of events and the nature of the appellants’ actions. The Court found that the fatal wounds were the four gunshot wounds inflicted by Ramon Jumawan after the appellants had mauled the victim. The mauling, while violent, was not the cause of death; the necropsy report conclusively established death was due to severe hemorrhage from the gunshot wounds. Therefore, there was no direct causal connection between the appellants’ acts of hitting with chairs and a bottle and the victim’s death.
Furthermore, the Court ruled the appellants’ actions constituted a justified act of defense of a relative under Article 11 of the Revised Penal Code. The sudden, unprovoked shooting of Wally Punzalan by the policeman, who was in plain clothes, naturally provoked intense passion, fear, and a desire for retaliation in defense of their fallen companion. Their subsequent mauling of the policeman was a spontaneous reaction to an unlawful aggression by the victim, who had just shot their friend. Their collective response, in the heat of the moment, was a legitimate defense of Wally. Consequently, they incurred no criminal liability. The Court ordered their immediate release but mandated the continued pursuit of Ramon Jumawan.