FACTS:

Amado Garcia was charged with murder for allegedly causing the death of Manuel Chy. The incidents leading to the case started on September 26, 1999, where petitioner, along with Fidel Foz Jr. and Armando Foz, had a drinking spree in Bogie Tacuboy's apartment. Chy, who lived adjacent to the apartment, asked them to quiet down, which angered petitioner.

Then, on September 28, 1999, the group gathered again for a wedding celebration. Maya Mabbun advised them to stop singing in order to avoid another confrontation with Chy. This further angered petitioner, who declared that he would not let Chy live long.

On September 29, 1999, the group met at the house of Foz and Garcia. Petitioner, Foz Jr., and Fred Rillon discussed the previous confrontations with Chy. Petitioner expressed his intent to finish off Chy that day. The group then went to Punta and passed by Chy's sister's (Aurelia Esquibel) store. Petitioner ordered Esquibel to call Chy, who was coming out of his house.

When Chy approached petitioner, he suddenly punched him in the face. Chy questioned why he was assaulted, but petitioner continued to attack him. Foz Jr. tried to intervene but was also hit. Petitioner then struck the back of Chy's head with a bottle of beer. Foz Jr. pushed Chy, causing him to fall.

Chy managed to escape and ran towards his house, where he called his wife to call the police. Chy complained of difficulty breathing. When the police arrived at Chy's house, they found him unconscious on the kitchen floor. Chy was pronounced dead upon arrival at the hospital, and the autopsy revealed that he died of myocardial infarction.

Petitioner was found guilty beyond reasonable doubt of homicide by the Regional Trial Court and was sentenced to an indeterminate prison term. The Court of Appeals affirmed the conviction, and petitioner's motion for reconsideration was denied. Petitioner now argues before the Supreme Court that he should be acquitted due to lack of evidence and reasonable doubt.

ISSUES:

1. Can the judge who did not hear the evidence and witness testimonies render a valid and just decision?

2. Is reliance on the transcripts of stenographic notes and observations of ordinary men sufficient to calibrate the testimonies of witnesses?

3. Whether the petitioner can be held criminally liable for the death of the victim despite the victim's pre-existing heart ailment.

4. Whether the award of moral damages is proper in cases of murder and homicide without the need for allegation and proof, other than the death of the victim.

5. Whether the amount of moral damages should be reduced.

RULING:

1. The judge who did not hear the evidence and witness testimonies can still render a valid and just decision based on the records on hand, such as the transcripts of stenographic notes. This does not violate substantive and procedural due process of law.

2. Reliance on the transcripts of stenographic notes and observations of ordinary men is sufficient to calibrate the testimonies of witnesses in accordance with their conformity to common experience, knowledge, and observation.

3. Yes, the petitioner can be held criminally liable for the death of the victim. The court held that the emotional strain from the beating aggravated the victim's delicate constitution and directly led to his death. The court applied Article 4(1) of the Revised Penal Code which states that criminal liability shall be incurred by any person committing a felony although the wrongful act done be different from that which he intended. The court further explained that a person committing a felony is responsible for all the natural and logical consequences resulting from it. The fact that the victim had a pre-existing heart ailment does not exempt the petitioner from criminal liability. However, the court appreciated the petitioner's lack of intention to commit such a grave wrong as a mitigating circumstance and imposed a lower penalty.

4. The award of moral damages is mandatory in cases of murder and homicide, without the need for allegation and proof, other than the death of the victim.

5. In accordance with controlling case law, the amount of moral damages should be reduced to P50,000.

PRINCIPLES:

• The efficacy of a decision is not necessarily impaired by the fact that the judge only took over from a colleague who had earlier presided over the trial.

• A judge who did not try a case in its entirety can decide it based on the records on hand, such as the transcripts of stenographic notes.

• Reliance on the transcripts of stenographic notes and observations of ordinary men does not violate substantive and procedural due process of law.

• Article 4(1) of the Revised Penal Code - Criminal liability shall be incurred by any person committing a felony although the wrongful act done be different from that which he intended.

• A person committing a felony is responsible for all the natural and logical consequences resulting from it.

• In cases where death results as a direct consequence of the use of illegal violence, the mere fact that the diseased or weakened condition of the injured person contributed to his death does not relieve the illegal aggressor of criminal responsibility.

• A person's lack of intention to commit so grave a wrong can be considered as a mitigating circumstance.

• In cases of murder and homicide, the award of moral damages is mandatory.

• The amount of moral damages can be reduced in accordance with controlling case law.