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People vs.

Sales
658 SCRA 367
GR No. 177218 October 2011

Facts:
On September 19, 2002, brothers Noemar and Junior, then nine and eight years old,
respectively, left their home to attend the fluvial procession of Our Lady of Peafrancia without
the permission of their parents. They did not return home that night. When their mother, Maria
Litan Sales (Maria), looked for them the next day, she found them in the nearby Barangay of
Magsaysay. Afraid of their fathers rage, Noemar and Junior initially refused to return home but
their mother prevailed upon them. When the two kids reached home a furious appellant
confronted them. Appellant then whipped them with a stick which was later broken so that he
brought his kids outside their house. With Noemars and Juniors hands and feet tied to a coconut
tree, appellant continued beating them with a thick piece of wood.

When the beating finally stopped, the three walked back to the house, Noemar collapsed and
lost consciousness. Maria then told appellant to call a quack doctor. He left and returned with
one, who told them that they have to bring Noemar to a hospital. Appellant thus proceeded to
take the unconscious Noemar to the junction and waited for a vehicle to take them to a
hospital. As there was no vehicle and because another quack doctor they met at the junction
told them that Noemar is already dead, appellant brought his son back to their house.

Appellant denied that his son died from his beating since no parent could kill his or her child. He
claimed that Noemar died as a result of difficulty in breathing. In fact, he never complained of
the whipping done to him. Besides, appellant recalled that Noemar was brought to a hospital
more than a year before September 2002 and diagnosed with having a weak heart.

On the other hand, Maria testified that Noemar suffered from epilepsy. Whenever he suffers from
epileptic seizures, Noemar froths and passes out. But he would regain consciousness after 15
minutes. His seizures normally occur whenever he gets hungry or when scolded.

The trial court charged the accused guilty of parricide and slight physical injuries.CA Affirmed.

Issue:

Whether Sales is criminally liable for the crime of patricide.

Rulings:

Yes. He is criminally liable for the crime of patricide. In the proceedings of the case,
Appellant attempts to evade criminal culpability by arguing that he merely intended to discipline
Noemar and not to kill him. However, the relevant portion of Article 4 of the Revised Penal Code
states
Art. 4. Criminal liability. Criminal liability shall be incurred:
1. By any person committing a felony (delito) although the wrongful
act done be different from that which he intended.

In order that a person may be criminally liable for a felony different from that which he intended
to commit, it is indispensible (a) that a felony was committed and (b) that the wrong done to the
aggrieved person be the direct consequence of the crime committed by the perpetrator.[20] Here,
there is no doubt appellant in beating his son Noemar and inflicting upon him physical injuries,
committed a felony. As a direct consequence of the beating suffered by the child, he
expired. Appellants criminal liability for the death of his son, Noemar, is thus clear.