People v Iligan

Topic​: Elements of Criminal Liability, Causation

Plaintiff-Appellee: ​People of the Philippines
Defendants-Appellants​: Fernando Fernando Iligan y Jamito, Edmundo Asis y Iligan and Juan Macandog Iligan

Facts​:
At around 2 in the morning Esmeraldo Quinones and his companions ZaldyAsis and Felix Lukban were walking home from barangay Sto. Domingo
after attending a barrio fiesta. On the way they met the accused Fernando Iligan and his nephew Edmundo Asis and Juan Macandog. Edmundo
Asis pushed them aside prompting Zaldy Asis to box him. Felix quickly said that they had no desire to fight. Upon seeing his nephew fall,Fernando
Iligan drew from his back a bolo and hacked Zaldy but missed.Terrified the trio ran, pursued by the three accused. They ran for a good while and
even passed the house of Quinones, when they noticed that they were no longer being chased the three decided to head back to Quinones house.
On the way back the three accused suddenly emerged from the road side, Fernando Iligan then hacked Quinones Jr.on the forehead with his bolo
causing him to fall down. Felix and Zaldy ran. Upon returning they saw that Quinones Jr. was already dead with his head busted.The postmortem
examination report and the death certificate indicates that the victim died of “ shock and massive cerebral hemorrhages due to vehicular accident.”

Issue:
Whether or not the accused are liable for the victim’s death given that it was dueto a vehicular accident and not the hacking.

Held:
Yes. We are convinced beyond peradventure that indeed after Quinones, Jr. had fallen from the bolo hacking perpetrated by Iligan, he was run
over by a vehicle. This finding, however, does not in any way exonerate Iligan from liability for the death of Quinones Jr. This being under ART 4 of
the RPC which states that criminal liability shall be incurred by any person committing a felony although the wrongful act done be different from that
which he intended. The essential requisites of Art 4 are: that an intentional felony has been committed and that the wrong done to the aggrieved
party be the direct natural and logical consequence of the felony committed by the offender .

It is held that the essential elements are present in this case. The intentional felony committed was the hacking of the head of Quinones the fact
that it was considered superficial by the physician is immaterial. The location of the wound intended to do away with him.The hacking incident
happened on the national highway where vehicles pass any moment, the hacking blow received by Quinones weakened him and was run over by
a vehicle. The hacking by Iligan is thus deemed as the proximate cause of the victim’s death.

Ruling: ​WHEREFORE, appellant Fernando Iligan y Jamito is hereby convicted of the crime of homicide for which he is imposed the
indeterminate penalty of six (6) years and one (1) day of prision mayor as minimum to fourteen (14) years, eight (8) months and one
(1) day of reclusion temporal medium as maximum and he shall indemnify the heirs of Esmeraldo Quiñones, Jr. in the amount of fty
thousand pesos (P50,000). Appellant Edmundo Asis is hereby acquitted of the crime charged against him. Costs against appellant Iligan.