PEOPLE OF THE PHILIPPINES vs. NOEL T.

SALES
G.R. No. 177218
DEL CASTILLO, J.:

ISSUE:
Whether or not Sales was responsible for the death of Noemar.

FACTS:
On September 19, 2002, brothers Noemar and Junior left their home to attend the fluvial
procession of Our Lady of Peñafrancia without their parents’ permission. They did not return
home that night. Their mother, Maria Litan Sales found them in the nearby barangay. Afraid of
their father’s rage, Noemar and Junior refused to return home but their mother prevailed upon
them. Upon reaching home a furious appellant confronted them. Appellant then whipped them
with a stick and brought his kids outside their house. With Noemar’s and Junior’s hands and feet
tied to a coconut tree, appellant continued beating them with a thick piece of wood. When the
beating finally stopped, 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. He claimed that
Noemar died as a result of difficulty in breathing being diagnosed last September 2002 of having
a weak heart. On the other hand, Maria testified that Noemar suffered from epilepsy. The RTC
charged the accused guilty of parricide and slight physical injuries. Appellant appealed to the
CA, however, the appellate court denied the appeal and affirmed the ruling of the RTC.

DECISION:
The appeal was denied for lack of merit. The contentions of appellant fail to persuade.
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: Criminal liability shall be incurred 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. 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. Appellant’s
criminal liability for the death of his son, Noemar, is thus clear.