People v. Escalona
REITERATIONFacts
The Antecedents: The accused, Pablo Escalona, a policeman, attacked a man named Bernardino Pisieng with a bolo while the latter was climbing out of a ravine. Pisieng sustained a wound on his wrist. Sixty days after the injury, Pisieng died. Procedural History: The Court of First Instance of Ilocos Sur convicted Pablo Escalona of homicide and sentenced him to twelve years and one day of reclusion temporal, accessory penalties, indemnity to the heirs of the deceased, and costs. The Petition: The accused appealed the judgment, admitting the wounding but questioning his liability for the death of Pisieng, arguing he should only be liable for lesiones (wounding) and not homicide. He cited the testimony of the municipal inspector of health.
Issue(s)
Whether the accused is liable for homicide when the victim died sixty days after the wounding. Whether the lack of proper medical attendance affects the classification of the crime.
Ruling
The judgment appealed from is affirmed, with a modification in the penalty. The accused Pablo Escalona shall be sentenced to fourteen years, eight months, and one day of reclusion temporal, with costs.
Ratio Decidendi
On whether the accused is liable for homicide when the victim died sixty days after the wounding: The Court affirmed the conviction for homicide. It was established that the death of Bernardino Pisieng occurred sixty days after he was wounded by Pablo Escalona. The municipal inspector of health testified that Pisieng died in consequence of the wound on his wrist, which had not healed at the time of his death. The witness further stated that the wounded man had severed tendons and a broken bone in his forearm, and suffered from fever until his death. The Court found that the death was a direct consequence of the injury inflicted by the accused. On whether the lack of proper medical attendance affects the classification of the crime: The Court held that the lack of proper medical attendance does not absolve the person who inflicted the wound from responsibility for the resulting death. The witness testified that he believed Pisieng would have recovered if he had been attended by a licensed surgeon who might have performed an amputation or provided other assistance. However, the Court, citing a previous judgment, stated that the lack of attendance cannot be attributed to the wounded man. Therefore, the person who caused the wound is responsible for the result thereof, regardless of whether better attendance could have saved the victim's life. The Court found no aggravating or mitigating circumstances present, and the penalty for homicide was imposed in the medium degree.
Main Doctrine
The person who inflicts a wound is responsible for the result thereof, even if the death might have been averted by proper medical attendance, as the lack of attendance cannot be attributed to the wounded party.