Seguritan v. People 4. A heated discussion ensued between Seguritan and Lucrecio.
Seguritan
G.R. No. 172896
19 April 2010 | Del Castillo, J. | Criminal liability – Wrongful act different from
that intended; proximate cause
PETITIONER: Rono Seguritan y Jara
RESPONDENTS: People of the Philippines (Lucrecio)
SUMMARY: Seguritan was having a drinking session with his uncles. An
argument ensued between him and Lucrecio. Seguritan punched Lucrecio. His
punches caused him to fall and hit an improvised stove. He went home and fell
asleep and was later on seen by his wife and daughter with a darkened
complexion and a frothing mouth. He died that night. Dr. Vertido declared that
his cause of death was due to a traumatic head injury. MHO Cabebe however
found that it was because of a heart attack. RTC and CA convicted him of
murder to which SC affirmed, holding that Seguritan punching Lucrecio was the
proximate cause of the latter’s death.
DOCTRINE: Art. 4, par. 1 of the RPC: Criminal liability — Criminal liability
shall be incurred:
(1) By any person committing a felony (delito) although the wrongful act done
be different from that which he intended.
He who is the cause of the cause is the cause of the evil caused.
FACTS:
1. Oct. 1, 1996 – Seguritan was charged with homicide (pleaded not guilty).
2. Nov. 25, 1995 - Seguritan was having a drinking session with his uncles:
a. Lucrecio
b. Melchor; and
c. Baltazar
3. Seguritan who was seated beside Lucrecio, claimed that Lucrecio's
carabao entered his farm and destroyed his crops.
punched Lucrecio twice as the latter was about to stand up. His punches
landed on Lucrecio’s right and left temple, causing him to fall face-up to
the ground and hit a hollow block (improvised stove).
5. Lucrecio lost consciousness but Baltazar revived him. Lucrecio went
home. Upon arrival, his wife noticed blood on his forehead to which he
explained that he was stoned. He went directly to his room and slept.
6. 9:00 pm – Wife and daughter noticed his darkened complexion and a
foamy substance which came out from his mouth. They tried to revive
him but failed. He died the same night.
7. Dec. 4, 1995 – Wife learned of Seguritan’s involvement in Lucrecio’s
death. She then asked the assistance of NBI Medico-Legal Office Dr.
Vertido to exhume his body and perform an autopsy.
8. Dr. Vertido concluded that the cause of Lucrecio’s death was traumatic
injury:
a. Hematomas in the scalp located in the right parietal and left
occipital areas
b. A linear fracture in the right middle fossa, and
c. A subdural hemorrhage in the right and left cerebral hemisphere
9. Seguritan denied hitting Lucrecio and alleged that the latter died of
cardiac arrest. He claimed that:
a. He suddenly stood up while they were having and that he
intended to punch Lucrecio.
b. However, since Lucrecio was seated at the opposite end of the
bench, Lucrecio lost his balance and fell before he could be hit.
Lucrecio's head hit the improvised stove as a result of which he
lost consciousness.
10. Seguritan presented MHO Joel Cabebe to prove that Lucrecio died of a
heart attack.
11. RTC convicted Seguritan guilty of homicide to which CA affirmed with
modification.
12. Seguritan filed an MR but CA denied. Thus this petition for review
Seguritan filed before the SC.
ISSUE:
1. WON Seguritan should only be held liable for reckless imprudence
resulting in homicide due to the absence of intent to kill Lucrecio. -
NO.
RATIO:
1. When death resulted, even if there was no intent to kill, the crime is
homicide, not just physical injuries. With respect to crimes of personal
violence, the penal law looks particularly to the material results
following the unlawful act and holds the aggressor responsible for all the
consequences thereof.
2. In view of Art. 4, par. 1 of the RPC, Seguritan committed an unlawful act
by punching Lucrecio, his uncle who was much older than him, and even
if he did not intend to cause the death of Lucrecio, he must be held guilty
beyond reasonable doubt for killing him pursuant to the said provision.
He who is the cause of the cause is the cause of the evil caused.