Monday, February 20, 2012

People vs. Ilustre (March 14, 1930)

Facts: A procession was held in the barrio of Canlurangbayan, Balayan. It is characteristic of this feast to make the rounds of the town in procession, with a roasted pig placed on a cane. It was customary that the people try to take a piece of barbecued pig. A man was placed in charge to direct the procession and prevent people from consuming the whole animal. Said man was the defendant. 

Juan Magsino, a young man who suffered from incipient tuberculosis, tried to get a piece of the crackling but the defendant boxed him and left him sprawling on the ground. Juan suddenly felt ill and died a few hours after the incident. 

Defendant was found guilty of willfully, unlawfully and feloniously dealing Juan Magsino a blow with his closed fist in the right hypochondriac region, bruising his liver and producing internal hemorrhage resulting in the death of the victim. Defendant appealed, stating that he 1) did not hit the victim, 2) the court erred in finding that said contusion was the direct cause of the victim’s death, 3) there is doubt as to the real cause of the victim’s death and 4) even if the defendant committed the crime, it was done without criminal intent. 

Issue: What was the cause of Juan Magsino’s death? 

Held: There was no disagreement among the medical witness who conducted the autopsy that the victim’s death was cause by the defendant’s blow 

The fact that the deceased had a delicate constitution and suffered from incipient pulmonary tuberculosis does not affect the defendant’s criminal liability for even if the rendered blow was more fatal; the efficient cause of death remains the same. And circumstance that the defendant did not intend so great an evil as the death of the victim does not exempt him from criminal liability, since he deliberately committed an act prohibited by law, but simply mitigates his guilt in accordance with article 9 of the RPC. 

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