URBANO v.

Intermediate Appellate Court

Case Name
Filomeno Urbano v. Hon. Intermediate Appellate Court and People of the Philippines
Topic Proximate Cause
Case No. |
L-72964 | 7 January 1988
Date
Ponente Gutierrez, Jr., J.
Case
Summary
Decision Petition is granted, Petitioner Acquitted
A person committing a felony is responsible for all the natural and logical consequences resulting
Doctrine from it although the unlawful act performed is different from the one he intended.

RELEVANT FACTS
• Marcelino Javier opened the irrigation of a canal by means of cutting grass which caused the
flooding of the storage area of the petitioner. Petitioner got angry and demanded Javier to pay for the
soaked palay. Javier refused and a quarrel between them ensued. Urbano unsheathed his bolo and
hacked Javier hitting him on the right hand and left leg. Javier went to the hospital for the treatment of
the wounds. Two weeks after, Javier returned to his farm and tended to his tobacco plants.

Then, on a fateful day of November 14, Javier was rushed to the hospital. Doctors findings showed that
he was suffering from tetanus infection. The next day, Javier died.

RTC and CA found the petitioner guilty beyond reasonable doubt of homicide. Petitioner raised the
case to the SC arguing that the cause of the death of Javier was due to his own negligence.

RATIO DECIDENDI
Issue Ratio
Was Urbano’s No
action the
proximate cause of  Pursuant to this provision “an accused is criminally responsible for acts
the death of committed by him in violation of law and for all the natural and logical
Javier? consequences resulting therefrom. The rule is that the death of the victim must
be the direct, natural, and logical consequence of the wounds inflicted upon
him by the accused
 The petitioner reiterates his position that the proximate cause of the death of
Marcelo Javier was due to his own negligence, that Dr. Mario Meneses found
 no tetanus in the injury, and that Javier got infected with tetanus when after
two weeks he returned to his farm and tended his tobacco plants with his bare
hands exposing the wound to harmful elements like tetanus germs.

 Consequently, Javier’s wound could have been infected with tetanus after the
hacking incident. Considering the circumstance surrounding Javier’s death,
his wound could have been infected by tetanus 2 or 3 or a few but not 20 to 22
days before he died. The medical findings, however, lead us to a distinct
possibility that the infection of the wound by tetanus was an efficient
intervening cause later or between the time Javier was wounded to the time of
his death. The infection was, therefore, distinct and foreign to the crime.

 And if an independent negligent act or defective condition sets into operation

the instances which result in injury because of the prior defective condition,
such subsequent act or condition is the proximate cause.

 CA’s decision was SET ASIDE and petioner is ACQUITED of the crime of
homicide.

RULING
WHEREFORE, instant petition is GRANTED. Questioned decision of IAC is REVERSED and SET ASIDE.
Petitioner is ACQUITTED
SEPARATE OPINION/S

NOTES