People vs. Villacorta
People vs. Villacorta
People vs. Villacorta
Facts:
● Villacorta was found guilty of murdering Danilo Salvador Cruz
○ 23 Jan 2002: Villacorta willfully stabbed Cruz with a sharpened bamboo stick
● Witnesses: Cristina Mendeja and Dr. Domingo Belandres
○ Mendeja’s account:
■ Cruz was ordering bread at her store at around 2pm when Villacorta
suddenly appeared and stabbed Cruz using a sharpened bamboo stick.
■ The bamboo stick broke and was left in Cruz’s body.
■ Villacorta fled the scene. Mendeja tried to chase him but was not able to
catch him.
■ When she returned to her store, she saw her neighbor Aron removing the
broken bamboo stick from Cruz’s body.
○ Dr. Belandres’ account
■ Cruz was taken to Tondo Medical Center when he sustained the wound
and was only brought to San Lazaro Hosp. on 14 Feb 2002 where he
died the following day.
■ He died of tetanus infection secondary to stab wound.
● Villacorta denied stabbing Cruz
○ Acc. to him, he was on his way home from work at 2am of 21 jan 2002.
○ Upon arriving home, he drank coffee and went outside to buy cigarettes at a
nearby store. As he was about to leave the store, Cruz put his arm around
Villacorta’s shoulder, which prompted him to box Cruz. After which, he went
home.
○ He did not notice that Cruz got hurt and was not aware of his death until he was
arrested.
WoN Mendeja Mendeja’s Not - Trial courts had the first had opportunity to
was a credible statements persuaded observe the demeanor of the witnesses under
witness were grilling examination. Both the RTC and CA
inconsistent gave full faith and credence to the testimony of
and Mendeja
incredulous - Villacorta was not able to present any reason
for Medeja to fabricate such a lie and falsely
accuse him
- Denial is self-serving negative evidence at the
face of a positive identification
WoN Villacorta The proximate Yes Art 266: Slight physical injuries and maltreatment
can be held cause1 of - Shall be punished by arresto menor when
liable only for death is the offender has inflicted physical injuries
slight physical infection, and which shall incapacitate the offended party
injuries for the not the stab from labor from 1-9 days or shall require
stab wound he wound medical assistance during the same period
inflicted upon
Cruz
WoN Villacorta Set aside - If Cruz acquired severe tetanus infection from
was guilty the stabbing, then the symptoms would have
beyond appeared a lot sooner than 22 days later
reasonable - He cannot be held criminally liable for
doubt of frustrated murder because the intent to kill
murdering Cruz was not established