People v. Quianzon
REITERATIONFacts
The Antecedents: During a novena in the house of Victoria Cacpal, Andres Aribuabo approached Juan Quianzon for food. Quianzon, annoyed, took a firebrand and applied it to Aribuabo's neck, exclaiming he was wounded and dying. Aribuabo showed a wound in his abdomen below the navel and died ten days later as a result of this wound. Procedural History: The Court of First Instance of Ilocos Norte convicted Juan Quianzon of homicide and sentenced him to an indeterminate penalty. The Petition: Juan Quianzon appealed the decision to the Supreme Court.
Issue(s)
Whether the testimony of Simeon Cacpal, found to be improbable and contradictory, should have been considered by the lower court. Whether the testimonies of Roman Bagabay, Gregorio Dumlao, and Julian Llaguno, who identified Juan Quianzon as the assailant, are credible. Whether the extrajudicial confessions of Juan Quianzon to the barrio lieutenant and chief of police are admissible and sufficient to establish his guilt. Whether the wound inflicted by the accused was the proximate cause of the victim's death, despite the victim's actions of removing medical drainage. Whether the crime committed was homicide or serious physical injuries.
Ruling
The Supreme Court affirmed the conviction for homicide but modified the penalty. The Court sentenced the appellant to an indeterminate penalty with a minimum of four years of prision correccional and a maximum of eight years of prision mayor, with costs to the appellant.
Ratio Decidendi
On the testimony of Simeon Cacpal: The Court found Simeon Cacpal's testimony improbable, incongruent, and contradictory, agreeing with the defense that it was an error for the lower court to have considered it. If Cacpal was a false witness, none of his statements could be taken into account. On the credibility of other witnesses: The testimonies of Roman Bagabay, Gregorio Dumlao, and Julian Llaguno were found to be credible and disinterested. Bagabay testified to seeing Quianzon apply a firebrand and admit to using a bamboo spit. Dumlao and Llaguno testified to Quianzon's confessions of wounding Aribuabo with a bamboo spit. The defense failed to assign any unlawful motive for these witnesses to testify falsely. On the admissibility of confessions: The victim's statement naming Quianzon as the assailant immediately after the wound, and Quianzon's subsequent admissions to Bagabay, Dumlao, and Llaguno, were considered competent evidence admissible as part of the res gestae. The extrajudicial confessions, corroborated and made freely and voluntarily, constituted evidence against him. On proximate cause and causation: The Court held that one who inflicts an injury is responsible for the death if the injury contributes mediately or immediately to it, even if other causes contribute. The victim's act of removing drainage, done possibly due to pain and pathological condition, did not alter the juridical consequences of the accused's act. The wound in the abdomen, which caused traumatic peritonitis due to perforation of the large intestine, was the determining factor in the death, and the possibility of survival without removing drainage did not absolve the accused. On the classification of the crime: The Court rejected the contention that the crime was only serious physical injuries. Applying established jurisprudence, the wound inflicted was the cause that determined the death. The possibility of survival does not diminish the criminality of the act, as the accused is responsible for the natural consequences of his actions. The Court cited precedents where death resulting from secondary hemorrhage or complications arising from the wound, even with patient's movements against medical advice, was considered homicide.
Main Doctrine
One who inflicts an injury on another is deemed guilty of homicide if the injury contributes mediately or immediately to the death of such other, and the fact that other causes contribute to the death does not relieve the actor of responsibility. The natural consequences of one's acts are contemplated and are the responsibility of the actor, and it does not diminish criminality to prove that other causes co-operated in producing the fatal result.