Download as docx, pdf, or txt
Download as docx, pdf, or txt
You are on page 1of 1

Urbano v.

IAC, 157 SCRA 1 (1998)

Facts:

 On October 23, 1980, petitioner Filomeno Urbano was on his way to his ricefield. He found
the place where he stored palay flooded with water coming from the irrigation canal. Urbano
went to the elevated portion to see what happened, and there he saw Marcelino Javier and
Emilio Efre cutting grass.
 Javier admitted that he was the one who opened the canal. A quarrel ensued, and Urbano hit
Javier on the right palm with his bolo, and again on the leg with the back of the bolo. On
October 27, 1980, Urbano and Javier had an amicable settlement. Urbano paid P700 for the
medical expenses of Javier.
 On November 14, 1980, Urbano was rushed to the hospital where he had lockjaw and
convulsions. The doctor found the condition to be caused by tetanus toxin which infected the
healing wound in his palm. He died the following day.
 Urbano was charged with homicide and was found guilty both by the trial court and on
appeal by the Court of Appeals. Urbano filed a motion for new trial based on the affidavit of
the Barangay Captain who stated that he saw the deceased catching fish in the shallow
irrigation canals on November 5. The motion was denied; hence, this petition.
Issue:
WON Urbano’s action was the proximate cause of the death of Javier.
Ruling:
NO. A definition of proximate cause is that cause, which, in natural and continuous sequence,
unbroken by any efficient intervening cause, produces the injury, and without which the result would
not have occurred.
The symptoms of tetanus appeared on the 22nd day after the hacking incident or more than 14 days
after the infliction of the wound.
The more credible conclusion is that at the time Javier’s wound was inflicted by the appellant, the
severe form of tetanus that killed him was not yet present. 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 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 proof that the accused caused the victim’s death must convince a rational mind beyond
reasonable doubt. 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.
The decision of the then Intermediate Appellate Court, now Court of Appeals, is REVERSED and
SET ASIDE. The petitioner is ACQUITTED of the crime of homicide. Costs de oficio.

You might also like