A.C. No. 5819 - Heirs of Tan, Sr. vs. Beltran

On May 21, 1970, at approximately 9:00 p.m. in San Nicolas, Ilocos Norte, Asuncion Pablo Ulep sustained fatal injuries.
The victim was the legally wedded wife of Macario A. Ulep, who later became the accused in the case.
The death occurred in the context of alleged physical aggression by her husband.

The autopsy was conducted at the request of the daughter of the deceased (from a previous marriage), even though the accused initially refused permission.
Dr. Eliseo V. Bonoan performed the autopsy shortly before the burial at the cemetery of San Nicolas.
Autopsy findings included:

Complete fractures of the 4th, 5th, 6th, and 7th ribs on the left chest and the 3rd and 4th ribs on the right chest.
A rectangular contusion on the upper half of the left arm.
Presence of 200 cc. of serous fluid in the thoracic cavity with lacerations of the pleura at fracture points.
Accumulation of 500 cc. of serous fluid in the abdominal cavity, with explanations offered regarding its nature.
Evidence in the cardiovascular and central nervous systems indicating clotted blood in the heart and congestion, yet considered within normal post-mortem findings.

The necropsy report concluded that death resulted from cardiac arrest and primary shock, ostensibly due to the strong pressure inflicted on the chest.

Two constabulary sergeants conducted separate investigations resulting in affidavits (Exhibits “A” and “B”) in which the accused admitted causing harm to his wife by delivering several elbow blows.
In his initial admissions, the accused explained that his wife was intoxicated and uttered indecent words; his aggressive response included elbowing her on the breast.
In a subsequent court appearance, the accused retracted these affidavits, claiming that an earlier incident (in February or March 1969) involving a bullcart accident was the cause of the injuries.
Despite the retraction, the trial judge observed that there was no genuine repudiation of the sworn statements where he admitted the cause of death being due to his elbow blows.

The defense argued that the fractures could have been the result of a longstanding condition or a separate accidental incident (involving a bullcart and a sack of rice), rather than recent physical blows.
The defense contended that:

The absence of contusions on the chest indicated that the elbow blows were insufficient to cause fractures (since significant force would result in swelling or contusion due to extravasated blood).
The nature of the fractures (complete fractures without depressed or cave-in characteristics) would not, by themselves, compress and injure the heart to cause cardiac arrest.
The serous fluid found in both the thoracic and abdominal cavities could be attributed to a chronic or natural process, as opposed to an acute traumatic shock.

The appellants relied on expert testimony (e.g., by Dr. Pedro Blanco) to suggest that natural disease and a longstanding weakening of the cardiac system were the proximate causes of death.

The prosecution maintained that the elbow blows were the proximate and efficient cause of death, causing strong physical pressure on the chest and leading directly to cardiac arrest and primary shock.
Expert opinions, including the assertion that the chest wall’s pliability can allow for significant compression even without depressed fractures, supported this view.
The prosecution also cited medical jurisprudence (notably from Wharton and Stille’s work) to underpin the concept that even transient shock from seemingly minor trauma can be fatal.

The Court of First Instance of Ilocos Norte, Second Judicial District found the accused guilty of parricide and sentenced him to reclusion perpetua.
An indemnity was imposed against the accused for the heirs of the deceased, initially fixed at P12,000.00 and later increased to P30,000.00 by the appellate ruling.

Was the death of Asuncion Pablo causally linked to the elbow blows inflicted by Macario Ulep resulting in fractured ribs, cardiac arrest, and primary shock?
Could alternative causes, such as a long standing medical condition, have contributed primarily or secondarily to the fatal outcome?

How reliable were the admissions made by the accused in his written statements (Exhibits “A” and “B”) and to what extent did his subsequent retraction affect the determination of cause?
What role did the autopsy findings, particularly the necropsy report of Dr. Bonoan, play in establishing the proximate cause of death?

Did the absence of marked contusions properly refute the possibility that elbow blows could cause the observed rib fractures?
Is the explanation provided by the defense, attributing the serous fluid accumulation to a chronic condition, sufficient to negate the traumatic origin of the injuries?

Does the principle that “he who is the cause of the cause is the cause of the evil caused” apply in recalibrating criminal liability in the presence of pre-existing medical conditions?