Tuesday, February 21, 2012

Li vs. People [G.R. No. 127962, April 14, 2004]

Facts: One morning in April 1993, street brawl ensued between Christopher Arugay and his neighbor, Kingstone Li. Arugay sustained multiple stab wounds causing his death while Li sustained hack wounds on the head and contusions. Two different versions of the incident were presented. According to the first version, Arugay was watching the television with his sisters Cristy and Baby Jane and Tan, boyfriend of Baby Jane, when they heard a noise caused by Li and Sangalang who were then bathing naked outside their house. Enraged, Arugay went outside and confronted the two which eventually ended up with Li striking Arugay with a baseball bat on the head and later stabbing him with a knife. Sangalang was also seen stabbing the victim at least once with a knife. The second version, offered by Li however presented that Li was watching the television with a friend when Arugay and his girlfriend hurled objects and kicked the gate of his house. Upon seeing that Arugay has gotten himself two kitchen knives, Li armed himself with a baseball bat. Li managed to evade Arugay’s thrusts and successfully hit him with the bat on the shoulder with which Arugay ran back to his house and emerged carrying a bolo. Arugay tried to hit Li with the bolo but Li raised his right hand to protect himself but Arugay was able to hit him on his right temple, right wrist, and right shoulder. Li passed out. Sangalang was also present when the incident started. Arugay died of multiple stab wounds while Li was brought to the hospital. 

RTC charged Li with homicide and ruled the existence of conspiracy although concluded that it was Sangalang, and not Li, who stabbed Arugay. Court of Appeals affirmed RTC’s decision but opined that since it has not been established which wound was inflicted by either one of them, they should both be held liable and each one is guilty of homicide, whether or not a conspiracy exists. 

Issue: Whether or not  there was conspiracy between Li and Sangalang. If there is not, what acts are imputable to Li. 

Held: No, RTC erred in concluding an implied conspiracy. The facts that Li and Sangalang were in the same house at the same time; and that they both armed themselves before going out to meet Arugay are not in themselves sufficient to establish conspiracy. 

Sangalang stabbed Arugay only after petitioner had become unconscious. Before that point, even as Li struck Arugay with a baseball bat, it was not proven that Li had asked for, or received, any assistance from Sangalang. Based on these circumstances, Sangalang and Li had not acted in concert to commit the offense. After Arugay had struck hack wounds on Li and as Li lay incapacitated, possibly unconscious, it remained highly doubtful whether he had any further participation in the brawl. At that point, Sangalang, emerged and stabbed Arugay to death. In fact, the stabbing of Arugay could very well be construed as a spur-of-the-moment reaction by Sangalang upon seeing that his friend Li was struck by Arugay. It cannot be assumed that Sangalang did what he did with the knowledge or assent of Li, much more in coordination with each other. It was also proved that Li, already weak and injured, could possibly inflict fatal stab wounds on Arugay. 

Absent any clear showing of conspiracy, Kingstone Li cannot answer for the crime of Eduardo Sangalang. Petitioner Kingstone Li is ACQUITTED of the charge of Homicide for lack of evidence beyond reasonable doubt. However, he is found GUILTY of the crime of SLIGHT PHYSICAL INJURIES.

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