Cases in Article 4: Incurring Criminal Liability

1) People vs. Mario Mariano: accused is criminally liable for the 6yr old death brought about by the rape committed even if it was only accidental as when she hit her head on the pavement while struggling WHY? Having performed an act constituting a felony, he is RESPONSIBLE for ALL the consequences of said act, regardless of his intention 2) US vs Brobst: one is not relieved from criminal liability for the natural consequences of ones illegal acts, merely because one does not intend to produce such consequences 3) People vs. Ural: rationale of Art4 (1): el que es cuausa de la causa del mal causado He who is the cause of the cause is the cause of the evil caused. 4) US vs Divino: defendant attempted to render medical assistance in good faith to cure the victim of ulcer by tying the girl and wrapping her feet with rags saturated of petroleum and thereafter set it on fire, causing burns. while there was no intention to cause an evil but to provide a remedy, accused was liable for injuries thru imprudence defendant is liable for 2 offenses (not intentional felony): a. physical injuries thru imprudence b. illegal practice of medicine 5) US vs Villanueva: one who snatched a bolo out of curiosity caused an injury to the other when he tried to retrieve his bolo is not liable for such injury WHY? There is no provision in the RPC which punishes that act of snatching the property of another just to satisfy curiosity 6) People vs. Bindoy: Pacas who was trying to retain the possession of the bolo of the accused who was having a quarrel with his wife when the latter refused to drink the tuba, is not liable for the death of Emigdio Omamdam when the bolo struck and pierce his breast WHY? There is no evidence to show that the accused injured Emigdio deliberately. He was only defending his possession of the bolo. attempted homicide if accused wanted to pierce Pacas but instead killed Emigdio provided that there is intent to kill 7) People vs Gona: accused wanted to assault Dunca butsince it was dark, he inflicted mortal wound with a bolo to Mapudul instead he is criminally liable for the death of Mapudul 8) People vs. Mabugat: accused fired a gun to Juana Buralo (his sweetheart who refused to take a walk with him because the accused visited another womans house) but because of lack or precision, hit Perfecta (niece of Juana). accused is guilty of frustrated murder qualified by treachery (because he shot the gun while his victims did not have any chance to protect themselves) 9) People vs Tomotorgo: the fact that the appellant intended to only maltreat his wife (because her actions angered him) or inflict physical injuries does not exempt him from liability for the resulting and more serious crime of parricide. 10) People vs. Monleon: maltreatment inlifted by the accused to his wife (castigated his wife because she prevented him from whipping his son who did not feed the carabao) was the proximate cause of her death. 11) People vs Salinas: Salinas who was trying to prevent Severino from having a bloody encounter with his father is not criminally liable for the death of Jaime Tibule (infant child of Mercuria) who died due to internal hemorrhage in the skull caused by Mercurias fall when she was trying to free Severino from the grip of Salinas. it cannot be said that the death of the child was the direct result of a crime which Crisanto Salinas committed or was in the act of committing. 12) People vs Toling: if a man creates in another persons mind an immediate sense of danger, shich causes such person to try to escape (death of a woman who jumped from the jeep), and in o doing, the latter injures himself, the man who creates such a state of mind is responsible for the resulting injuries. reason: when accused threatened to shoot, he was already committing a felony (Art294: attempted robbery with intimidation) 13) US vs Zamora; US vs Sornito: a person is criminally responsible for acts committed byb

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him in violation of the law and for all the natural and logical consequences resulting therefrom. 14) People vs. Illustre: blow was efficient cause of death: the accused was liable for homicide when the blows he gave to the deceased who was suffering from tuberculosis produced internal hemorrhage which resulted to his death. 15) People vs. Rodriguez: blow accelerated death: accused was liable for homicide because his fist blows produced the cause for the acceleration of the death of the deceased. 16) US vs Marasigan: the offended party is not obliged to submit to a surgical operation to relieve the accused from the natural and ordinary results of his crime. It was his voluntary act which disabled Mendoza and he must abide by the consequences resulting therefrom without aid from Mendoza/ 17) People vs Martir: an accused is liable for all the consequences of his acts, and the infection of a wound he has caused is one of the consequences for which he is answerable. 18) Peopls vs Quianson: Victim was injured in the abdomen. He took out the drainage from his wound and as a result of the peritonitis that developed, he died. Accused is still liable for his death because it was the natural consequence of he mortal wound inflicted. 19) People vs Reloj: Accused stabbed the victim with an ice pick. Victim had a successful operation. 5days later he died due to paralytic ileum which was the consequence of the exposure of the internal organs during the operation. Accused is responsible for the natural consequences of his own acts. 20) Quinto vs Andres: Offender is criminally liable for the death of the victim if his delictual act caused, accelerated or contributed to the death of the victim. A different doctrine would tend to give immunity to crime and take away from human life a salutary and essential safeguard. 21) Bataclan vs Medina: Was it the overturning of the bus or the fire started because of the torch the proximate cause of the death of the 4 passengers? It was the overturning of the bus. The leaking of the gasoline was not unnatural or unexpected, the coming of the men

with the torch was to be expected and was a natural sequence of the overturning of the bus. 22) People vs Luces: Ramon Luces gave a fist blow on the stomach of his wife Feliciana who fall to the ground and a few seconds later died. In the autopsy it was found that she dies due to cardiac failure. Gravity of the crime does not depend on the more or less violent means used but on the result and consequence of the same. If the accused had not ill-treated the deceased, she would not have died. The fist blow was the proximate cause of her death. Art 266: ill-treating another by deed without causing any injury 23) People vs Piamonte: victim was stabbed Oct 28, 1951, he died dec 28. While the wounds inflicted were not the immediate cause, they were however the proximate cause of death. This is enough to make the accused responsible for the crim charged. 24) People vs Tammang: Boy Jundam was whipped, spanked and thrown against the post by his teacher resulting to chest pains and continous vomiting died 3 days afterwards. There being no proof of any intervening cause, the liability of the teacher for homicide necessarily follows from the premises stated. 25) People vs Cagoco: accused hit the victim who fell and hit his head on the asphalt pavement which resulted to his death. Accused was liable although he did not intend to kill the victim. #injurious result is greater than that intended 26) People vs Rellin: if the consequences produces have resulted from a distinct act or fact absolutely foreign from the criminal act, the offender is not responsible for such consequences. #not direct, natural and logical consequence of the felony committed. 27) People vs Rockwell: a person struck another with his fist and knocked him down. A horse nearby jumped upon him and killed him. The assailant is not responsible for his death. #not direct, natural and logical consequence of the felony committed. 28) US vs Delos Santos: accused cannot be held liable for the SERIOUS physical injuries of the victim. Former caused slight physical injuries upon the latter, because the act of the victim (deliberately immersing himself to the pool

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which contaminated his wound) was the proximate cause of the serious physical injuries. #not direct, natural and logical consequence of the felony committed. 29) People vs Morallos: the neglect of the wound or its unskillful and improper treatment, which are of themselves consequences of the criminal act and which might naturally follow in any case, must in law be deemed to have been among those consequences which were in contemplation of the guilty party and for which he is to be held responsible. 30) People vs Petilla: where the charge contained in the original information was for slight physical injuries because at the time the fiscal believed that the wound will heal within 8 days, but during the PI, it was discovered that the would took 30days to heal. The supervening event converted the crime from slight to serious physical injuries and such can be the subject of a change of the charge without necessarily placing the accused in double jeopardy.

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