PEOPLE V. NOEL T.SALES ( G.R. NO.

177218, OCTOBER 3, 2011)

FACTS:

In the night of September 2002 in Camarines Sur, appellant Noel R. Sales beaten his two
(2) sons Noel Sales Jr. and Noelmar because they failed to return home after joining the fluvial
procession of Our Lady of Penafrancia. Sales whipped his son with a piece of wood
approximately one meter in length and one and a half inches in diameter. After finish beating his
sons, his wife, Maria noticed that there was a crack in the head of Noemar so they brought him to
a quack doctor, who said that Noemar was already dead.

Appellant held Noemar while on their way to the crossroad and observed his difficulty in
breathing. The pupils of Noemar’s eye were also moving up and down. Appelant heard him say
that he wanted to sleep and saw him pointing to his chest in pain. However, they waited in vain
since the vehicle never came. It was then that Noemar died. Appellant thus decided to just bring
Noemar back to their house. Noemar was never examined by a physician and after a days of his
wake he was buried. Thereafter, his father surrendered and after trial, the RTC found Sales guilty
beyond reasonable doubt of the crime of PARRICIDE and sentenced to suffer the penalty of
reclusion perpetua. Sales appealed before the Court of Appeals but the CA denied the decision
of the RTC.

Appellant raised the argument that Noemar died not during his whipping. To substantiate
his claim, appeallant presented his wife who testified that Noemar indeed suffered seizures and
this was due to epilepsy.

ISSUE:

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

RULING:

YES. Appellant attempts to evade criminal culpability by arguing that merely intended to
discipline Noemar and not to kill him. However, the relevant portion of Article 4 of the RPC
states:

Art. 4. Criminal Liabilty – 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.
Xxx

In order that a person may be criminally liable for a felony different from that which he
intended to commit, it is indispensable that a felony was committed and that the wrong done to
the aggrieved person be the direct consequence of the crime committed by the perpetrator.
 In the case at bar, 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. THE APPEAL IS DENIED.1