People v. Reyes
REITERATIONFacts
The Antecedents: The appellant was convicted of homicide for the death of Fausta Tavera. The deceased had been living with the appellant but returned to her parents, who demanded a dowry before marriage. On the evening of the crime, after a barrio procession and dance, the deceased informed the appellant she would not return to him and would go with her parents. The appellant then dragged her towards the street and stabbed her in the chest with a fanknife. The deceased ran to the house of the barrio lieutenant and fell dead at the foot of the staircase. The wound was superficial, not penetrating the thoracic cavity. Procedural History: The Court of First Instance of Camarines Sur convicted the appellant of homicide. The Petition: The appellant contended that he could not be convicted of homicide as the wound inflicted was superficial and not of intrinsic magnitude, and that the State must prove the deceased did not die of other causes. He also claimed he was attacked by relatives of the deceased and the wound was accidental. The trial court appreciated the mitigating circumstances of lack of intention to commit so grave a wrong and sufficient provocation.
Issue(s)
Whether the appellant can be convicted of homicide when the wound inflicted was superficial. Whether the State has the burden to prove the deceased did not die of other causes. Whether the circumstances of the case warranted the appreciation of mitigating circumstances.
Ruling
The Supreme Court affirmed the conviction, modifying the sentence. The Court held the appellant guilty of homicide without aggravating or mitigating circumstances and sentenced him to eight years of prision mayor to fourteen years, eight months, and one day of reclusion temporal, and to indemnify the heirs of the offended party in the sum of P1,000.
Ratio Decidendi
On whether the appellant can be convicted of homicide when the wound inflicted was superficial: The Court held that the appellant is responsible for the consequences of his criminal act. The deceased ran screaming to a nearby house and died shortly after. The sanitary inspector testified that the deceased died from shock as a result of the wound, which was superficial. The Court reiterated the principle that a person is responsible for the consequences of his criminal act, and even if the deceased had a pre-existing condition, the appellant's assault being the proximate cause of death would make him responsible. The means employed, stabbing with a fanknife, contradicted the claim of lack of intention to commit homicide. On whether the State has the burden to prove the deceased did not die of other causes: The Court stated that it is well-settled in Philippine jurisdiction that the State does not have the burden to prove that the deceased did not die of poisoning or some other cause. A person is responsible for the consequences of his criminal act. The fact that no proper autopsy was conducted due to the death occurring in an outlying barrio does not shift the burden of proof to the State to disprove other causes of death. On whether the circumstances of the case warranted the appreciation of mitigating circumstances: The Court found that the trial court erred in appreciating the mitigating circumstance of lack of intention to commit so grave a wrong, as stabbing with a lethal weapon like a fanknife upon a vital part of the body implies an intent to cause death or serious injury, and death could reasonably be anticipated. The Court also found that the trial court erred in appreciating sufficient provocation, as the law requires provocation to come from the offended party, and the deceased's refusal to renew her relationship with the appellant did not constitute legal provocation. The appellant's claim of being attacked was found to be contrary to the prosecution's witnesses and weakened by his own statement to the chief of police.
Main Doctrine
A person is responsible for the consequences of his criminal act, and even if the deceased had been shown to be suffering from a diseased heart, the assailant's act being the proximate cause of death, he would be responsible. The means employed in an assault can contradict a claim of lack of intention to commit homicide.