AMADO ALVARADO GARCIA vs.

PEOPLE OF
THE PHILIPPINES (G.R. No. 171951, August
28, 2009)
SEPTEMBER 9, 2016 / RUSSELL JAY

Subject: Criminal Law 1- Proximate cause

Ponente: Associate Justice Leonardo Quisimbing

Doctrine: A person committing a felony is responsible for all the natural

and logical consequences resulting from it although the unlawful act
performed is different from the one he intended.

FACTS: Amado Garcia and Fidel Foz Jr., had a drinking spree in the
morning of September 1999 that lasted the until the evening of that day.
Because of the blaring noise of the videoke machine that the two were
enjoying, Manuel Chy, told the group to quiet down. Two days after, the
met again on a wedding and again, Chy told the two to stop singing. On the
next day, the two, now with a friend, decided to have a drinking session
and later moved to Punta.
On their way to Punta, they saw Chy. The petitioner suddenly assaulted
Chy and struck him on the lower part of his head with a bottle. When Chy
found a way to escape, he rushed to his home and phoned his wife and told
her to call the police. When they arrived, they found Chy unconcsious and
later pronounced dead on arrival at the hospital

The petitioner was found guilty beyond reasonable doubt of homicide. The
petitioner contended that he should only be charged with slight physical
injuries as his assault on Chy was not he cause of his death.

ISSUE: WON Garcia is liable for Manuel Chy’s death

RULING: YES. It can be reasonably inferred from the foregoing
statements that the emotional strain from the beating aggravated Chy’s
delicate constitution and led to his death. The inevitable conclusion then
surfaces that the myocardial infarction suffered by the victim was the
direct, natural and logical consequence of the felony that petitioner had
intended to commit.
The essential requisites for the application of this Article 4 of the RPC are:
(a) the intended act is felonious; (b) the resulting act is likewise a felony;
and (c) the unintended albeit graver wrong was primarily caused by the
actor’s wrongful acts. Hence, the fact that Chy was previously afflicted
with a heart ailment does not alter petitioner’s liability for his death. a
person committing a felony is responsible for all the natural and logical
consequences resulting from it although the unlawful act performed is
different from the one he intended.