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People vs Ortega (276 SCRA 166)

Facts:
In 1992, Benjamin Ortega, Jr., Manuel Garcia and a certain John Doe were charged with murder for the
killing Andre Man Masangkay. As narrated by a witness, the victim answered the call of nature and went
to the back portion of the house where they were having a drinking spree. Accused Ortega followed him
and later they heard the victim shouting for help and when they ran towards the scene he saw the
accused on top of the victim and stabbing the latter with along bladed weapon. Thereafter, Ortega and
Garcia brought the victim to a well and dropped him and placed stones into the well. The trial court
found the accused guilty beyond reasonable doubt. The accused appealed averring that the trial court
erred in holding them criminally liable because at the time the victim was dropped into the well, he was
still alive.
Issue:
Whether or not the accused may be held criminally liable for the death of the victim which is not
attributable to the stab wounds but due to drowning?
Decision:
A person who commits a felony is criminally liable for the direct natural and logical consequences of his
wrongful act even where the resulting crime is more serious than that intended. The essential requisites
for this criminal liability to attach are as follows:
1. the intended act is felonious.
2. the resulting act is likewise a felony
3. the unintended graven wrong was primarily caused by the actors wrongful acts.