People vs. Almonte

G.R. No. 35066
Purificacion Almonte stabbed Felix Te Sue, her former partner, causing a wound that led to his death due to a secondary hemorrhage. The Supreme Court ruled her guilty of homicide, citing the wound as the proximate cause, with mitigating circumstances reducing her penalty.
homicide cause of death internal hemorrhage

Case Digest (G.R. No. 35066)

Facts:

The People of the Philippine Islands v. Purificacion Almonte, G.R. No. 35066, September 07, 1931, the Supreme Court, Imperial, J., writing for the Court. The plaintiff-appellee is The People of the Philippine Islands; the defendant-appellant is Purificacion Almonte.

On or about October 1, 1930, in Sorsogon, Purificacion Almonte stabbed Felix Te Sue with a small penknife, producing a wound in the left abdominal region near the umbilicus. Te Sue and Almonte had previously lived maritally; they had recently separated after Te Sue returned to live with another woman. Almonte visited Te Sue’s house, was pushed, and in reaction stabbed him. Te Sue was taken to the provincial hospital where Dr. Eduardo Ortega cleaned and sutured the wound. The doctor testified the cut penetrated muscle but did not reach internal organs and would have healed in about a week if uncomplicated.

Although there was no primary hemorrhage, after about twenty-four hours the patient suffered a secondary internal hemorrhage and died on the sixth day from complications. Dr. Ortega testified that the wound caused internal congestion of veins such that any unnecessary movement could precipitate rupture and bleeding; Te Sue, despite being advised to remain still and being tied down for the operation, repeatedly sat up and walked about, allegedly because the bed was too warm and he was unaccustomed to it. Relatives and hospital attendants watched him, and he received medical treatment.

At trial the accused pleaded not guilty, was convicted of homicide, and sentenced to fourteen years, eight months, and one day of reclusion temporal, ordered to indemnify the heirs P1,000, and to pay costs. Almonte appealed, raising four assignments of error: (I) the trial court erred in attributing the deceased’s movements to pain from the wound; (II) the trial court erred in holding her criminally responsible for the secondary hemorrhage; (III) the trial court erred in finding th...(Pro-only)

Issues:

  • Was the accused criminally responsible for the death of Felix Te Sue, given that death resulted from a secondary internal hemorrhage after movements by the victim?
  • Should the accused’s conviction be for homicide as charged, or for a lesser offense such as slight or serious physical injuries?
  • Were mitigating circumstances present so as to reduce the penalty, and how should se...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)
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