FILOMENO URBANO vs. CA (G.R. No.

72964 January 7, 1988)

Subject: Criminal Law- Proximate Cause

Ponente: Justice Hugo Guitierrez, Jr.

Doctrine: Proximate legal cause is that acting first and producing the injury,
either immediately or by setting other events in motion, all constituting a
natural and continuous chain of events, each having a close causal
connection with its immediate predecessor, the final event in the chain
immediately effecting the injury as a natural and probable result of the cause
which first acted, under such circumstances that the person responsible for
the first event should, as an ordinarily prudent and intelligent person, have
reasonable ground to expect at the moment of his act or default that an
injury to some person might probably result therefrom.

FACTS: Marcelino Javier opened the irrigation of a canal by means of cutting

grass which caused the flooding of the storage area of the petitioner. Petitioner
got angry and demanded Javier to pay for the soaked palay. Javier refused and a
quarrel between them ensued. Urbano unsheathed his bolo and hacked Javier
hitting him on the right hand and left leg. Javier went to the hospital for the
treatment of the wounds. Two weeks after, Javier returned to his farm and
tended to his tobacco plants.
Then, on a fateful day of November 14, Javier was rushed to the hospital. Doctors
findings showed that he was suffering from tetanus infection. The next day,
Javier died.

RTC and CA found the petitioner guilty beyond reasonable doubt of homicide.
Petitioner raised the case to the SC arguing that the cause of the death of Javier
was due to his own negligence.

ISSUE: WON Urbano’s action was the proximate cause of the death of Javier.

RULING: NO. Pursuant to this provision “an accused is criminally responsible for
acts committed by him in violation of law and for all the natural and logical
consequences resulting therefrom. The rule is that the death of the victim must
be the direct, natural, and logical consequence of the wounds inflicted upon him by
the accused
The petitioner reiterates his position that the proximate cause of the death of
Marcelo Javier was due to his own negligence, that Dr. Mario Meneses found no
tetanus in the injury, and that Javier got infected with tetanus when after two
weeks he returned to his farm and tended his tobacco plants with his bare hands
exposing the wound to harmful elements like tetanus germs.

Consequently, Javier’s wound could have been infected with tetanus after the
hacking incident. Considering the circumstance surrounding Javier’s death, his
wound could have been infected by tetanus 2 or 3 or a few but not 20 to 22 days
before he died. The medical findings, however, lead us to a distinct possibility
that the infection of the wound by tetanus was an efficient intervening cause
later or between the time Javier was wounded to the time of his death. The
infection was, therefore, distinct and foreign to the crime.

And if an independent negligent act or defective condition sets into operation the
instances which result in injury because of the prior defective condition, such
subsequent act or condition is the proximate cause.

CA’s decision was SET ASIDE and petioner is ACQUITED of the crime of homicide.