Case Digest (G.R. No. 72964) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Filomeno Urbano, petitioner Filomeno Urbano was prosecuted for homicide before the Circuit Criminal Court of Dagupan City, Third Judicial District, following an altercation on October 23, 1980 in Barangay Anonang, San Fabian, Pangasinan. At around 8:00 a.m., Urbano discovered his stored palay flooded by irrigation water allegedly released by Marcelo Javier and confronted him and his companion, Emilio Erfe, at the elevated portion of the canal. A quarrel ensued when Javier admitted responsibility, and Urbano hacked Javier with a two-foot bolo, inflicting a two-inch incised wound on Javier’s right palm and a secondary blow to his left leg. Javier, unarmed, fled but was overtaken; further hacking was prevented only by Urbano’s daughter. Javier was treated by Dr. Mario Meneses and later examined for medico-legal purposes by Dr. Guillermo Padilla, who certified a seven-to-nine-day incapacity. Through the intervention of Barangay Councilman Felipe Solis Case Digest (G.R. No. 72964) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Circumstances of the Hacking
- On October 23, 1980 at about 8:00 AM, petitioner Filomeno Urbano went to his ricefield in Barangay Anonang, San Fabian, Pangasinan, found his palay flooded by an overflowed irrigation canal and confronted Marcelo Javier and Emilio Erfe, who admitted opening the canal.
- A quarrel ensued. Urbano unsheathed a bolo and hacked Javier on the right palm (used to parry the blow) and subsequently on the left leg, causing swelling. Further hacking was prevented by Urbano’s daughter.
- Initial Medical Attention and Amicable Settlement
- Javier was brought first to Dr. Mario Meneses for treatment, then to Dr. Guillermo Padilla for medico-legal examination, who certified a 2-inch incised wound on the right palm with a 7–9 day incapacity.
- On October 27, 1980, mediated by Barangay Councilman Felipe Solis, Urbano and Javier formalized an amicable settlement at the San Fabian Police Station: Urbano agreed to pay ₱700 for medical expenses (₱400 advanced there; ₱300 paid on November 3).
- Onset of Tetanus and Death
- On November 14, 1980 (22 days after the incident), Javier was rushed to Nazareth General Hospital with trismus (lockjaw) and convulsions; Dr. Edmundo Exconde diagnosed tetanus infection of the healing wound.
- Javier died on November 15, 1980 at 4:18 PM despite resuscitation efforts.
- Criminal Proceedings and New Evidence
- An information for homicide was filed April 10, 1981; upon trial, the Circuit Criminal Court convicted Urbano, sentencing him to 12 years prision mayor as minimum to 17 years, 4 months, 1 day reclusion temporal as maximum, and ordered indemnity of ₱12,000 to the heirs.
- The Intermediate Appellate Court affirmed conviction and increased indemnity to ₱30,000. Urbano’s motion for new trial, based on an affidavit by Barangay Captain Soliven claiming Javier caught fish in shallow canals after a typhoon (possible independent infection source), was denied. Urbano petitioned the Supreme Court.
Issues:
- Whether Urbano’s hacking of Javier is criminally responsible for Javier’s subsequent death under Article 4, Revised Penal Code, as the natural and logical consequence of the unlawful act.
- Whether an efficient intervening cause—tetanus infection occurring well after the wound was inflicted—breaks the causal chain and exculpates Urbano from homicide liability.
- Whether the amicable settlement under PD No. 1508, Section 2(3), extinguished Urbano’s criminal liability for any injury inflicted.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)