Case No. 1 – Art.

3 of RPC
PEOPLE vs. CENTENO
G.R. No. L-33284 April 20, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLANDO CENTENO, ET AL.,
defendants. ROLANDO CENTENO, defendant appellant.

Facts:
 On the afternoon of December 1, 1968, Rolando Santos with Dionisio Violago, Eulogio
Villanueva, and their other companions were having a drink at the store of Aling Goreng, when
Policeman Valeriano Reyes approached Santos, boxed him in the chest when he protested, and
forcibly brought the latter to the police station.
 At the police station, Santos loudly objected his detention which prompted the respondent,
Police Chief Rolando Centeno, to administer his first karate blow on the nape of Santos’ neck
while he was being held in the arm by Reyes. The victim fell forward on the backrest of a bench.
 Centeno gave two more karate blows that crumpled Santos to the cement floor where he lay
prostrate and motionless. Centeno then ordered his policemen to bring the victim inside the
locker room adjacent to the municipal jail.
 The theory of the defense was that Santos was so intoxicated that he reeled and fell and hit his
head and suffered the internal brain hemorrhage that killed him. To support this claim, Chief
forensic chemist of the NBI testified that at the time of Santos's death, he had 0.21% of alcohol
in his blood.

Issue:
Whether or not the karate blows delivered by Centeno to Santos, without necessarily producing
contusions or abrasions, caused brain hemorrhage and the eventual death of the victim

Held:
 Dr. Vidal explained that even if no marks were left on the neck, karate blows could cause the
generalized and extensive bleedings that caused the victim's death. When the karate blows
delivered with the hypothenar on a muscular portion of the body like the nape, there will be no
external injuries, but the injury is internal.
 There was treachery or alevosia resulting to murder because Santos was suddenly attacked from
behind when in his weakened and intoxicated condition, coupled with the fact that his arm was
then being held by Reyes, he could not defend himself.
 The term of imprisonment was correctly fixed at reclusion perpetua, the medium penalty for
murder. The civil indemnity is, however, increased to P30,000.00 consistent with present policy.