Case Summary (G.R. No. L-49430)
Factual Background
On October 23, 1980, Urbano found his rice harvest flooded by water from an irrigation canal. He confronted Javier and Emilio Erfe, who had opened the canal. In the ensuing quarrel, Urbano hacked Javier with a two-foot bolo, inflicting a two-inch incised wound on the right palm and a hack on the left leg. Urbano’s daughter intervened to prevent further injury. Javier was initially treated by Dr. Meneses, then examined by Dr. Padilla, who issued a medico-legal certificate estimating a 7–9-day incapacitation.
Amicable Settlement and Subsequent Events
Through Councilman Solis’s intercession, Urbano and Javier reached an amicable settlement on October 27, 1980, under Presidential Decree No. 1508. Urbano advanced Php 700 for Javier’s medical expenses. On November 14, 1980, Javier was admitted to Nazareth General Hospital exhibiting tetanus symptoms (lockjaw, convulsions); he died the following day. Dr. Exconde concluded death resulted from tetanus infection of the healing wound.
Procedural History
An information for homicide was filed on April 10, 1981, before the Circuit Criminal Court of Dagupan City. After trial, Urbano was convicted and sentenced to an indeterminate term (12 years prision mayor minimum to 17 years, 4 months and 1 day reclusion temporal maximum) and ordered to indemnify Javier’s heirs (Php 12,000). On appeal, the Intermediate Appellate Court affirmed the conviction, increased indemnity to Php 30,000, and denied Urbano’s motion for new trial. Urbano then petitioned the Supreme Court.
Applicable Constitution and Legal Framework
Decision Date: January 7, 1988. The 1973 Constitution applies. Governing laws include Article 4(1) of the Revised Penal Code (criminal liability for all natural and logical consequences of one’s unlawful act) and P.D. 1508, Section 2(3) (settlement of minor offenses).
Issue
Whether Urbano’s hacking, which caused a wound later infected with tetanus, renders him criminally liable for Javier’s death, or whether an intervening cause and the barangay settlement bar homicide liability.
Analysis on Proximate Cause
The Court defined proximate cause as the first act that directly produces the injury in a continuous sequence unbroken by any efficient intervening cause. Lower courts held that tetanus infection was a natural and logical consequence of the hacking, citing medical testimony that the disease entered through the wound.
Consideration of Intervening Cause
Reviewing tetanus’ incubation (2–56 days, most within 14) and onset periods, the Court found it medically improbable that a severe infection existed immediately after the October 23 wound. Symptoms appeared 22 days later with rapid progression, suggesting infection occurred sometime afte
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Facts of the Incident
- On October 23, 1980 at about 8:00 a.m., petitioner Filomeno Urbano inspected his flooded palay stored near an irrigation canal in Barangay Anonang, San Fabian, Pangasinan.
- Urbano confronted Marcelo Javier and Emilio Erfe on top of the canal embankment; Javier admitted opening the sluice gates.
- A quarrel ensued and Urbano unsheathed a two-foot bolo, hacking Javier on the right palm as he parried the blow.
- Javier fled but was overtaken and hacked again on the left leg; further injury was prevented by Urbano’s daughter.
- Javier was taken home by companions, reported the incident to police, and received initial medical attention from Dr. Mario Meneses.
- On September 28, 1981, Dr. Guillermo Padilla issued a medico-legal certificate noting a two-inch incised wound on Javier’s right palm with a 7–9 day incapacity period.
- Urbano and Javier settled amicably on October 27, 1980 before Police Station personnel and Barangay Councilman Solis; Urbano advanced ₱400, later completing ₱700 in medical expenses.
- On November 14, 1980, Javier was rushed to Nazareth General Hospital exhibiting lockjaw and convulsions; Dr. Edmundo Exconde diagnosed tetanus infection.
- Javier died on November 15, 1980 at 4:18 p.m.; hospital records confirmed sudden cessation of respiration after muscular spasm.
Procedural History
- April 10, 1981: Information for homicide filed against Urbano in the Circuit Criminal Court of Dagupan City.
- Trial court found Urbano guilty beyond reasonable doubt of homicide and imposed an indeterminate prison term (12 years prision mayor to 17 years, 4 months & 1 day reclusion temporal), ordered indemnity of ₱12,000 to heirs, and costs.
- Intermediate Appellate Court (IAC) af