People v. Song
REITERATIONFacts
The Antecedents: On August 29, 1982, during a dance in Barangay Resurreccion, San Fernando, Masbate, accused-appellant Elmo Labriaga was seen handing a machete to co-accused Dennis Song, who was intoxicated. Both entered the dance hall. Labriaga then held Percival Alcovendas, while Song stabbed the victim on the left side of his back with the machete. The two assailants fled. The victim, Percival Alcovendas, was brought to the hospital and confined for five days. He developed high fever and hypertension and died. The attending physician's diagnosis was cardiac arrest, stab wound, and acute peritonitis, secondary. Procedural History: Song eluded arrest, and the case proceeded against Labriaga. The Regional Trial Court of Masbate found Labriaga guilty of murder and sentenced him to reclusion perpetua, with civil indemnity and moral damages. The case against Song was ordered archived. The Petition: Accused-appellant Labriaga appealed, contending that the stab wound was not the proximate cause of death and that his guilt was not proven beyond reasonable doubt.
Issue(s)
Whether the stab wound inflicted by co-accused Dennis Song was the proximate cause of the victim's death. Whether the guilt of accused-appellant Elmo Labriaga was proven beyond reasonable doubt, considering the eyewitness testimonies and the defense of denial.
Ruling
The Supreme Court affirmed the trial court's decision, finding the guilt of accused-appellant Elmo Labriaga established beyond reasonable doubt. The judgment was affirmed with the sole modification of increasing the death indemnity to P50,000.00.
Ratio Decidendi
On the issue of proximate cause: The Court held that the stab wound inflicted by Song was the proximate cause of Percival Alcovendas' death. Dr. Bailon testified that the victim died of acute peritonitis secondary to the stab wound, which injured his intestines. The acute peritonitis was a direct and natural consequence of the stab wound. The Court reiterated the settled rule that one who inflicts an injury is responsible for the death of the victim, even if the deceased might have recovered with proper care, or if unskilled or improper treatment aggravated the wound. The principle is that every person is responsible for the natural consequences of his acts, and if a wound puts life in jeopardy, and death follows as a consequence, it does not alter the nature or diminish the criminality to prove that other causes cooperated in producing the fatal result. Neglect or unskillful treatment, being consequences that might naturally follow, are deemed to have been contemplated by the guilty party. On the issue of guilt beyond reasonable doubt: The Court found that the prosecution established the guilt of accused-appellant Labriaga beyond reasonable doubt through the positive and unwavering identification by eyewitnesses Patrocino Albano and Dominica Alcovendas. These witnesses, who knew Labriaga as they resided in the same barangay, clearly saw him hold the victim while Song inflicted the stab wound. The crime scene was well-lighted, and the witnesses had unobstructed views. Labriaga's defense of denial was unconvincing and contradicted by the positive testimonies of the prosecution witnesses. The testimony of Pfc. Darlie Alvarez, stating the victim identified only Song, was deemed insufficient to create doubt, as the victim was in a hurry to be taken to the hospital and could only utter a single statement. Furthermore, the investigator included Labriaga in the complaint because he was seen holding the victim during the stabbing, as testified by other witnesses during the preliminary investigation. The Court found that the concerted action of Labriaga and Song, with Labriaga providing the weapon and holding the victim while Song stabbed him, demonstrated conspiracy and treachery, qualifying the crime as murder.
Main Doctrine
An individual who inflicts an injury is responsible for the death of the victim, even if the death is aggravated by improper medical treatment, as the law holds one responsible for the natural consequences of his acts.