People of the Philippines vs Noel T.

Sales
G.R.No. 177218, October 3, 2011

Facts:
        
On the night September 10, 2002 in Tinambac, Camarines Sur, Noel Jr. and Noelmar failed to
return home after joining the fluvial procession of Our Lady of Peñafrancia that made Noel T. Sales
beat his sons. The respondent used an approximately one meter in length and one and a half
inches in diameter piece of wood to whipped his sons. After he punished his sons, his wife Maria
noticed a crack on Noemar's head, and the couple brought him to a quack doctor who said that the
boy was dead already.
The respondent held the boy victim who was obviously in pain on their way to the hospital.
They waited at the crossroad, which not even a vehicle came, that was then Noemar died. They
decided to bring the boy back home and had only a day wake and his body was never examined
by a physician. The respondent surrendered to the police the day after.
The RTC found the respondent guilty of parricide and sentenced the penalty of reclusion
perpetua. The respondent appealed to CA, but only to affirmed the previous verdict.
The respondent argued that Noemar died not because of the whipping, but the victim suffered
seizures due to epilepsy, in which his claim was affirmed by his wife who testified about it.

Issue:
       
 Whether or not the respondent Noel T. Sales was responsible for the death of his son
Noemar.

Ruling:
        
Yes. Though the respondent contended that he merely intended to discipline and not to kill his
son, Noemar, death here is the direct result of the cause. In order that a person may be criminally
liable for a felony different from that which he intended to commit, it is indispensable stand that a
felony was committed, and that the wrong done to the aggrieved person be the direct consequence
of the crime committed by the perpetrator. A portion of Article 4 of the Revised Penal Code states:
 Art.4 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.
In the case at bar, there is no doubt that the respondent committed a felony by beating his son
and inflicting physical injuries till the victim died as a direct consequence.