The People of the Philippines vs .

Juan Quianzon
G.R. No. 42607 September 28, 1935

Facts:

On February 1, 1934, in the house of Victoria Cacpal at the barrio, near the Poblacion of
Paoay, Ilocos Norte, a novena for the suffrage of the soul of the deceased was held with
the attendance of relatives and friends including Andres Aribuabo.

Aribuabo went to the kitchen and asked for food from Juan Quianzon which was in
Quianzon’s care. This has irritated Quianzon, as it was the second or third time
Aribuabo approached him for the same purpose. Quianzon took a firebrand and struck
Aribuabo, the latter immediately ran to the gathering crying that he was wounded and
dying while showing the wound in his abdomen below the navel.

With the foregoing facts, the one responsible for wounding Aribuabo should be
determined; thus summoning Simeon Cacpal, Roman Bagabay, to the witness stand,
as they were present during the gathering. As well as Gregorio Dumalao and Julian
Llaguno who took part on the investigation.

Simeon Cacpal claimed that he had witnessed the wounding by Juan Quianzon to
Andres Aribuabo. However, Cacpal’s testimony were improbable, incongruent and
contradictory. Roman Bagabay’s claimed that he saw Juan Quianzon apply a firebrand
to the neck of Aribuabo who afterwards ran to the area where everyone was gathered,
exclaiming that he was wounded and identifying Quianzon as the person who wounded
him. Bagabay further testified that he asked Quianzon and Quianzon admitted that he
attacked Aribuabo with a bamboo spit. Gregorio Dumalao, the barrio lieutenant who
conducted the initial investigation also testified that Aribuabo claimed that it was
Quianzon who wounded him. Quianzon also stated that it was him who wounded
Aribuabo with a bamboo spit, when he was questioned by Dumalao.

Quianzon was later brought to the Chief of Police of Paoay, Juan Llaguno, for
questioning, where Quianzon confessed that he had applied a firebrand to Aribuabo’s
neck and later wounded him a with a bamboo spit. However, before the confession was
put into writing, Quianzon in retracted and denying that he had wounded Aribuabo with
a bamboo spit, and only admitting applying a firebrand to Aribuabo’s neck.

However, the statements of Bagabay, Dumalao and Llaguno were contradicted by

Simeon Cacpal, the witness for the prosecution as he testified that he had not seen
them speak neither to Aribuabo no to Quianzon in the afternoon of the crime. With this,
the defense invoked Cacpal’s testimony for discrediting the other witnesses for the
prosection is undefensible, as proved that Bagabay, Dumalao and Llaguno has no
unlawful, corrupt or wicked motive for them to testify falsely. Wherein Bagabay is not
related to the deceased, Dumlao was a nephew of the accused, while Llaguno was
purely in compliance with his official duties. The court believed this claim of the defense
as true.

Aribuabo died on the tenth day after the incident as a result of an infection of the wound
he obtained from the incident. Wherein, a drainage had been placed to control or
isolate the infection, or traumatic peritonitis where Aribuabo twice attempted to remove.

Issue :
Whether or not Quianzon is criminally liable to the homicide of Andres Aribuabo.
Held :

With Cacpal’s testimony being discharged, the evidence of the prosection relative to
Quianzon’s criminal liability for the death of Andres Aribuabo, consists of the following:

1. Statements as part of the res gestae wherein, Andres Aribuabo’s naming the
accussed as the one who attacked him, immediately after receiving the wound,
and the accussed’s admission that he had applied a firebrand nto Aribuabo’s
neck and had wounded him.
2. The extrajudicial confession of the accused, admitting that he inflicted the victim
with a bamboo spit in the same afternoon of the crime.

And despite the contention of the defense that the accused should not be convicted with
homicide, but only of serious physical injuries as the wound was not considered fatal
and he may have survived it had he not twice removed the drainage. According to Dr.
Mendoza who examined Aribuabo, the wound inflicted may occassionally result into
traumatic peritonitis , and considered as a fatal consequence. The element of the
patient’s act in due to severe pain does not alter the judicial consequences of the
punishable act of the accussed.

One who inflicts an injury on another is deemed by the law to be guilty of

homicide if the injury contributes mediately or immediately to the death of such
other. The fact that the other causes contribute to the death does not relieve the
actor of responsibility. . . . (13 R. C.L., 748.)

Furthermore, it is assumed that the patient had unconsciously removed the drainage
due to pathological condition and state of health brought by the severe pain that he was
experiencing.

As the mitigating circumstances of lack of instruction and of intention to commit so

grave a wrong as that committed should be taken into consideration in favor of the
appellant, without any aggravating circumstances adverse to him. The appealed
judgement was modified thru sentencing him to an indeterminate penalty with a
minimun of four years of prison correccional, and a maximum of eight years of prision
mayor, affirming it in all other respects, with costs to said Appellant.