People v. Ulep
REITERATIONFacts
The Antecedents: On May 21, 1970, Asuncion Pablo Ulep died as a result of physical injuries inflicted by her husband, Macario A. Ulep. Initially, the death was reported as due to a heart attack, and the husband refused an autopsy. However, the daughter of the deceased requested an autopsy, which was conducted by Dr. Eliseo Bonoan shortly before burial. Procedural History: The autopsy report indicated the cause of death as cardiac arrest and primary shock, with complete fractures of several ribs on both sides of the chest and lacerations of the pleura. Two weeks after the burial, the accused admitted in sworn statements (Exhibits "A" and "B") to having caused his wife's death by elbowing her in the breast because she was drunk and uttering indecent words. In court, the accused retracted these statements, claiming his wife had been injured by a bullcart more than a year prior. The Petition: The accused appealed his conviction for parricide, arguing that the lower court erred in holding that the cause of death was due to his elbow blows, and in not holding that the death was due to a long-standing condition, thereby erroneously convicting him.
Issue(s)
Whether the lower court erred in holding that the cause of death of Asuncion Pablo was due to the elbow blows by the accused-appellant. Whether the lower court erred in not holding that the cause of death was due to a long-standing process or condition in her body system. Whether the lower court erred consequently in not acquitting the accused of the crime of parricide.
Ruling
The Supreme Court affirmed the conviction of the accused-appellant for parricide, with a modification increasing the indemnity to the heirs of the deceased. The Court found that the physical injuries inflicted by the accused were the proximate cause or accelerant of the victim's death, despite the defense's claims of a pre-existing condition.
Ratio Decidendi
On the issue of the cause of death: The Court found no fundamental disagreement between the medical witnesses regarding the cause of death being cardiac arrest and primary shock. Dr. Bonoan's necropsy report, which found fractured ribs and concluded cardiac arrest and primary shock as the cause of death, was given credence. The Court noted that the defense's argument that the fractures could not have caused cardiac arrest because they were not depressed fractures was unconvincing, especially in light of the accused's admission of inflicting blows. The Court cited medical jurisprudence stating that death can result from shock attendant upon an injury, even if the injury appears unimportant or leaves no trace. Furthermore, even if the victim had a pre-existing ailment, if the blow delivered by the accused was the efficient cause of death, accelerated death, or was the proximate cause of death, criminal liability attaches. The Court emphasized the doctrine, "He who is the cause of the cause is the cause of the evil caused," as the rationale for Article 4 of the Revised Penal Code. On the issue of the defense's claim of a long-standing condition: The Court found the defense's theory that the death was due to a long-standing condition unconvincing. While the defense presented a witness who testified about a prior incident involving a bullcart, this testimony was vague regarding the specific ribs fractured and the extent of the injuries. The defense's medical witness, Dr. Blanco, admitted to not having attended a case of fractured ribs and had a simplistic understanding of cardiac failure. The Court found the explanation of Dr. Bonoan regarding the presence of serous fluid in the thoracic and abdominal cavities more cogent than that of Dr. Blanco. The Court also noted that the accused's initial admission of guilt in sworn statements (Exhibits "A" and "B") was a significant factor, and his retraction in court was not persuasive, especially since the trial judge observed that there was never an attempt to repudiate these sworn statements. On the issue of acquittal: Given the evidence, including the accused's admissions and the medical findings, the Court concluded that the accused was responsible for the death of his wife. The physical injuries inflicted by the accused were deemed the proximate cause of the cardiac arrest and primary shock that resulted in the victim's death. Therefore, the lower court did not err in convicting him of parricide.
Main Doctrine
The accused, who admitted to having inflicted physical injuries upon his wife, is held liable for her death, even if the defense argues that the death was due to a pre-existing condition, as the inflicted injuries were found to be the proximate cause or accelerant of death.