PEOPLE v. VILLACORTA G.R.

186412 (September 7, 2011) proximate cause

AGAPITO
Facts:
Danilo Cruz(Cruz) went to a sari-sari store to buy bread. Out of nowhere, Orlito
Villacorta(Villacorta) appeared and thereafter stabbed the left part of the body of Cruz with a
sharpened bamboo stick. After that, Villacorta fled.

Cruz was helped by bystanders and he was brought to a nearby hospital where he was treated as
out-patient. He was discharged on the same day but on February 14, 2002, or 21 days after the
stabbing incident, he returned to the same hospital where he was treated for severe tetanus. The
next day on February 15, 2002, Cruz died. The medical report states that Cruz died of tetanus
infection secondary to stab wound.

The trial court as well as the Court of Appeals convicted Villacorta for murder.

Villacorta that in the event he is found to have indeed stabbed Cruz, he should only be held liable
for slight physical injuries for the stab wound he inflicted upon Cruz.

Issue/s: W/N Villacorta should be convicted of murder. (NO)

Ruling:
No. Only slight physical injuries.

The SC agreed to the contention of Villacorta. The proximate cause of Cruz’s death is the tetanus
infection, and not the stab wound. Proximate cause has been defined as:

“that cause, which, in natural and continuous sequence, unbroken by any

efficient intervening cause, produces the injury, and without which the
result would not have occurred.”

The rule is that the death of the victim must be the direct, natural, and logical consequence of
the wounds inflicted upon him by the accused. And since we are dealing with a criminal
conviction, the proof that the accused caused the victim’s death must convince a rational mind
beyond reasonable doubt.

In this case, however, there was an efficient intervening cause which appeared between the time
of the stabbing and the time of the death of Cruz. The SC took into consideration the fact that
severe tetanus (the kind of tetanus which causes immediate death) has an incubation period of
14 days or less. In this case, the stabbing made by Villacorta could not have caused the tetanus
infection as 22 days already lapsed from the time of the stabbing until the date of death of
Cruz. Something else caused the tetanus other than the stabbing – in short, Cruz acquired the
tetanus 14 days or less before February 15, 2003 and not on the date of stabbing.

The medical findings, lead us to a distinct possibility that the infection of the wound by
tetanus was an efficient intervening cause later or between the time Cruz was wounded to
the time of his death. The infection was, therefore, distinct and foreign to the crime. As
such, Villacorta is only guilty of slight physical injuries.