People v. Cabonialda
REITERATIONFacts
The Antecedents: On October 24, 1927, in the barrio of San Antonio, municipality of Basey, Province of Samar, Arcadio Tabunda went to a well to draw water. Elias Cabonialda, suspecting Tabunda of taking palawan leaves from his orchard, attacked Tabunda with a stick, rendering him unconscious. Feliciana Baya, who lived with Tabunda, witnessed Cabonialda beating Tabunda. Tabunda was helped home and subsequently became ill, suffering pains and swelling in his abdomen, shoulder, and left forearm. He died twenty-one days later. Procedural History: The Court of First Instance of Samar found Elias Cabonialda guilty of homicide and sentenced him to fourteen years, eight months, and one day of reclusion temporal, with indemnity and costs. The Petition: Elias Cabonialda appealed the judgment, asserting self-defense and questioning the causation of death.
Issue(s)
Whether the appellant acted in self-defense. Whether the appellant is liable for homicide despite the victim's pre-existing physical condition.
Ruling
The judgment of the Court of First Instance of Samar is affirmed. The appellant is found guilty of homicide.
Ratio Decidendi
On the issue of self-defense: The Court rejected the appellant's claim of self-defense. The appellant alleged that he was the offended party and that the deceased initiated the attack. However, the Court found this incredible, especially considering the deceased was described as crippled, smaller, and thinner than the appellant. The Court also dismissed the appellant's claim that the deceased fell, deeming it highly improbable and unproven as the cause of death. On the issue of causation and pre-existing condition: The Court affirmed the appellant's liability for homicide. While acknowledging that the deceased had a prior accident three years earlier which incapacitated him for heavy work, the Court noted that he still enjoyed relatively good health and could engage in field labor. The fact that the deceased had gone to the well to fetch water prior to the assault indicated his functional capacity. Even if the blows received contributed to his death due to his weakened state, this circumstance did not exempt the appellant from liability, citing previous jurisprudence (U. S. vs. Samea, 15 Phil., 227; U. S. vs. Fenix, 11 Phil., 95). The Court held that the appellant's actions were the proximate cause of the death, or at least a contributing factor, and thus he must be held responsible.
Main Doctrine
A pre-existing physical condition of the victim does not exempt the offender from liability if the blows inflicted contributed to the death.