Li vs People

Date: April 14, 2004

Petitioner: Kingston Li
Respondents: People of the Philippines
Nature: Appeal from a decision of the Regional Trial Court of Makati City, Br. 148
Ponente: Tinga, J.
Facts: - Kingston Li and Eduardo Sangalang were involved in a street brawl against Christopher
Arugay and Ronaldo Tan.
- The defense and prosecution presented different stories regarding the facts of the case.
The following are the facts of the case based on the assessment made by the Supreme Court.
- The first blow was struck by Li who was armed with a baseball bat. It hit Arugay, whom
retaliated by inflicting a wound on Lis head using a bolo. After Li had fallen, Sangalang, armed
with a knife, fatally stabbed Arugay at least four times. Tan picked the baseball bat and struck Li
on the head with a bat.
- Arugay died while Li sustained incised wounds and a contusion. A case was filed
against Li while Sangalang has remained at large.
- The RTC found Li guilty of conspiring with Sangalang with the murder of Arugay. The
CA on the other hand ruled that both are guilty of homicide, whether or not conspiracy exists. Li
appealed. Thus, this case.
Issue: WON a conspiracy exists between Li and Sangalang.
WON Li is guilty of homicide.
Held: No in both issues. Judgment modified.
Ratio: - The fact that both Li and Sangalang were in the same house at the same is not sufficient
to establish conspiracy. Before the brawl, it was not proven that Li has asked for, or received, any
assistance from Sangalang and based on the evidences it is hard to conclude that Sangalang and
Li had acted in concert to commit the offense.
- Stabbing Arugay can be construed as a spur of the moment reaction by Sangalang upon
seeing that his friend was struck on the head. A finding of conspiracy cannot arise from such
spontaneous reaction.
- Since Lis liability as a conspirator was dissolved, he can only be convicted based on
the act that he did. The only injury attributable to Li is the contusion on the victims right arm
that resulted from Li striking Arugay with a baseball bat. His offense is only slight physical
injuries. Since Li has served more than the impossible penalty for slight physical injury, he is
entitled to be released immediately.