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ROLLIE CALIMUTAN v. PEOPLE

FACTS:

Petitioner Rollie Calimutan is seeking the reversal of his conviction for the crime of homicide. The prosecution presented witnesses who testified that Calimutan threw a stone at the victim, resulting in his death. The Municipal Health Officer initially determined the cause of death as cardio-respiratory arrest due to suspected food poisoning, but a subsequent autopsy conducted by Dr. Ronaldo B. Mendez revealed that the victim died from a lacerated spleen. Calimutan testified that he threw the stone in self-defense and had no personal grudge against the victim. The trial court found Calimutan guilty of homicide, and the Court of Appeals affirmed his conviction. Calimutan appealed to the Supreme Court. The main issue is the cause of death of the victim. The defense argues that the conflicting autopsy reports create reasonable doubt as to Calimutan's liability, while the prosecution relies on the expert testimony of Dr. Mendez. The Supreme Court found sufficient proof beyond reasonable doubt to hold Calimutan liable for the victim's death, based on Dr. Mendez's expert testimony and other resource materials on abdominal injuries.

ISSUES:

  1. Whether the stone thrown by the petitioner caused the laceration of the victim's spleen and subsequently resulted in his death.

  2. Whether the findings and testimony of Dr. Mendez as an expert witness should be given weight and probative value.

  3. Whether the cause of the victim's death was a lacerated spleen resulting from being hit by a stone thrown by the petitioner.

  4. Whether the post-mortem report and testimony of a doctor indicating food poisoning as the cause of death raise reasonable doubt as to the cause of death.

  5. Whether the findings of the medical examiner or the forensic pathologist should be given more weight in determining the cause of death.

  6. Whether the prosecution's failure to present a witness listed in its information constitutes suppression of evidence.

  7. Whether or not petitioner Calimutan is guilty beyond reasonable doubt of reckless imprudence resulting in homicide

RULING:

  1. The stone thrown by the petitioner caused the laceration of the victim's spleen and resulted in his death. Dr. Mendez, a Senior Medico-Legal Officer of the NBI and an expert witness, testified that the spleen could be lacerated or ruptured when the abdominal area was hit with a blunt object, such as the stone thrown by the petitioner. Dr. Mendez's testimony, along with reference to other resource materials, supported the conclusion that the stone caused the victim's death. The court held that the findings and testimony of Dr. Mendez should be seriously considered as they are evidence and establish the causal relationship between the stone thrown by the petitioner and the lacerated spleen of the victim.

  2. The findings and testimony of Dr. Mendez as an expert witness should be given great weight and probative value. Dr. Mendez, being an expert in pathology, surgery, gynecology, toxicology, and other branches of medicine, is presumed to possess sufficient knowledge in these fields. His testimony, which explained the cause of death based on his thorough autopsy and expertise, should be accorded the necessary weight and consideration by the court.

  3. The Court ruled that the victim's cause of death was a lacerated spleen resulting from being hit by a stone thrown by the petitioner. The testimony of witnesses and evidence presented proved that the victim was physically fine before being hit by the petitioner, and his condition rapidly deteriorated until he ultimately died. No other instances of blunt force trauma were found, thus establishing a causal link between the stone thrown and the lacerated spleen.

  4. The Court did not give weight to the post-mortem report and testimony of the doctor indicating food poisoning as the cause of death. The post-mortem report did not categorically state that food poisoning was the cause of death, and there was no confirmation from further laboratory tests. The doctor's sworn statement clarified that the mention of food poisoning was a suspicion and recommended further examination to confirm it. In contrast, the exhaustive autopsy conducted by another doctor revealed the traumatic injury of the abdomen, specifically the spleen, as the cause of death.

  5. The court gives more weight to the findings of the forensic pathologist. The court acknowledges that the forensic pathologist performed an exhaustive autopsy and made a definitive finding on the cause of death. Thus, the court affirms the forensic pathologist's conclusion that the cause of death was a ruptured spleen caused by the stone thrown by the petitioner.

  6. The court rules that the prosecution's failure to present a witness listed in its information does not amount to suppression of evidence. The prosecutor has the prerogative to determine which witnesses to present, and it is not necessary to present all witnesses if sufficient evidence has already been presented to establish guilt beyond reasonable doubt.

  7. Petitioner Calimutan is found guilty beyond reasonable doubt of reckless imprudence resulting in homicide. He is sentenced to imprisonment for a minimum period of 4 months of arresto mayor to a maximum period of two years and one day of prision correccional. Petitioner Calimutan is also ordered to pay the heirs of the victim Cantre the amount of P50,000.00 as civil indemnity for the latter's death and P50,000.00 as moral damages.

PRINCIPLES:

  • Expert witness testimony should be given great weight and probative value when the witness has sufficient knowledge and qualifications in their respective field of expertise.

  • Proximate cause is that cause which, in natural and continuous sequence, unbroken by any efficient intervening cause, produces the injury, and without which the result would not have occurred.

  • Causal link - The court established a causal link between the petitioner's act of throwing a stone and the victim's lacerated spleen resulting in death.

  • Weight of evidence - The court did not give weight to the post-mortem report and testimony of a doctor that did not conclusively establish the cause of death.

  • The court gives more weight to the findings of a forensic pathologist over a medical examiner in determining the cause of death.

  • The prosecutor has the prerogative to determine which witnesses to present, and the non-presentation of corroborative witnesses does not constitute suppression of evidence.

  • In determining criminal liability, the act committed must be accompanied by intent or negligence. If the act is unintentional or lacks due care, it may still give rise to civil liability.

  • Reckless imprudence consists of voluntarily, but without malice, doing or failing to do an act from which material damage results by reason of an accident or an unforeseen event.

  • In determining civil liability arising from a crime, the court looks into whether the accused acted with malice or negligence. If the act was done with malice, then the accused may be held civilly and criminally liable. If the act was done with negligence or imprudence, then the accused may be held civilly liable but not criminally liable.