People v. Moldes
REITERATIONFacts
The Antecedents: On the night of April 3, 1934, during a dance in Abuyog, Leyte, the appellant, Inocentes Moldes, was reprimanded by the deceased, who was the master of ceremonies, for insisting on dancing out of turn. In response, the appellant went to the porch, cut down decorations, descended into the yard, and challenged everyone to a fight. When his challenge did not attract sufficient attention, he began chopping bamboo trees and repeated his challenge. The deceased, unarmed, approached the appellant in a friendly manner. As the deceased reached the ground, the appellant struck him with a bolo, inflicting a serious incised wound on his left arm. The deceased fell, and the appellant inflicted a slight wound on his back before fleeing. The deceased was treated by a local 'curandero' but died on April 15, 1934, due to hemorrhage. Procedural History: The appellant was convicted of homicide by the Court of First Instance of Leyte. The Petition: The appellant appealed the decision, arguing that he did not intend to inflict a serious wound, acted in self-defense, and that the deceased's subsequent medical treatment contributed to his death.
Issue(s)
Whether the appellant acted in self-defense. Whether the medical treatment received by the deceased was the proximate cause of his death.
Ruling
The judgment of the Court of First Instance of Leyte, finding the appellant guilty of homicide and sentencing him to six years and one day of prision mayor to fourteen years, eight months, and one day of reclusion temporal, is affirmed.
Ratio Decidendi
On the issue of self-defense: The Court found no element of self-defense in the case, establishing the appellant as the aggressor. The appellant's actions, including challenging others to a fight and resorting to a lethal weapon, demonstrated his intent to harm. The Court reiterated the principle that when a person uses a lethal weapon and strikes another with sufficient force, it must be presumed that they realize the natural consequences of their act. The defense's theory that the deceased was the aggressor and that the appellant acted in self-defense was not believed by the trial court, and the appellate court found the prosecution's testimony to be clearer and more convincing. The attorney's contention that the appellant did not intend to commit as serious a wound was dismissed, as the use of a lethal weapon implies an intent to cause harm commensurate with its nature. On the issue of proximate cause: The Court rejected the contention that the deceased's lack of proper surgical treatment was the proximate cause of his death. Citing established legal authorities such as Corpus Juris and Ruling Case Law, the Court affirmed the general rule that the person who inflicts a dangerous wound is not relieved of responsibility if the wound inflicted is calculated to endanger life, even if the immediate cause of death was erroneous or unskillful medical treatment. The Court emphasized that a different doctrine would grant immunity to crime and undermine the safeguards of human life, as it would be easy to create doubt regarding the immediate cause of death amidst conflicting medical theories. The Court also referenced its own ruling in United States vs. Escalona (12 Phil., 54), which adopted the same rule, thereby holding the appellant responsible for the natural consequences of his felonious act.
Main Doctrine
The person who inflicts a dangerous wound, calculated to endanger life, is responsible for the death of the victim, even if the immediate cause of death was erroneous or unskillful medical treatment, as the perpetrator is presumed to contemplate the natural consequences of their act.