The People of the Philippines vs .

Juan Quianzon
G.R. No. 42607 September 28, 1935

Facts:
On February 1, 1934, in the house of Victoria Cacpal at the barrio, near the Poblacion of Paoay, Ilocos
Norte, a novena for the suffrage of the soul of the deceased was held with the attendance of relatives
and friends including Andres Aribuabo. Between 1500 hours to 1600 hours, Aribuabo went to the
kitchen and asked for food from Juan Quianzon which was in Quianzon’s care. This has irritated
Quianzon, as it was the second or third time Aribuabo approached him for the same purpose. Quianzon
took a firebrand and struck Aribuabo, the latter immediately ran to the gathering crying that he was
wounded and dying while showing the wound in his abdomen below the navel.

With the foregoing facts, the one responsible for wounding Aribuabo should be determined; thus
summoning Simeon Cacpal, Roman Bagabay, to the witness stand, as they were present during the
gathering. As well as Gregorio Dumalao and Julian Llaguno who took part on the investigation.

Simeon Cacpal claimed that he had witnessed the wounding by Juan Quianzon to Andres Aribuabo.
However, Cacpal’s testimony were improbable, incongruent and contradictory. Roman Bagabay’s
claimed that he saw Juan Quianzon apply a firebrand to the neck of Aribuabo who afterwards ran to the
area where everyone was gathered, exclaiming that he was wounded and identifying Quianzon as the
person who wounded him. Bagabay further testified that he asked Quianzon and Quianzon admitted
that he attacked Aribuabo with a bamboo spit. Gregorio Dumalao, the barrio lieutenant who conducted
the initial investigation also testified that Aribuabo claimed that it was Quianzon who wounded him.
Quianzon also stated that it was him who wounded Aribuabo with a bamboo spit, when he was
questioned by Dumalao.

Quianzon was later brought to the Chief of Police of Paoay, Juan Llaguno, for questioning, where
Quianzon confessed that he had applied a firebrand to Aribuabo’s neck and later wounded him a with
a bamboo spit. However, before the confession was put into writing, Quianzon in retracted and denying
that he had wounded Aribuabo with a bamboo spit, and only admitting applying a firebrand to Aribuabo’s
neck.

However, the statements of Bagabay, Dumalao and Llaguno were contradicted by Simeon Cacpal, the
witness for the prosecution as he testified that he had not seen them speak neither to Aribuabo no to
Quianzon in the afternoon of the crime. With this, the defense invoked Cacpal’s testimony for
discrediting the other witnesses for the prosection is undefensible, as proved that Bagabay, Dumalao
and Llaguno has no unlawful, corrupt or wicked motive for them to testify falsely. Wherein Bagabay is
not related to the deceased, Dumlao was a nephew of the accused, while Llaguno was purely in
compliance with his official duties. The court believed this claim of the defense as true

Aribuabo died on the tenth day after the incident as a result of an infection of the wound he obtained
from the incident. Wherein, a drainage had been placed to control or isolate the infection, or traumatic
peritonitis where Aribuabo twice attempted to remove.

Issue :
Whether or not Quianzon is criminally liable to the homicide of Andres Aribuabo.

Held :

With Cacpal’s testimony being discharged, the evidence of the prosection relative to Quianzon’s
criminal liability for the death of Andres Aribuabo, consists of the following:

1. Statements as part of the res gestae wherein, Andres Aribuabo’s naming the accussed as the
one who attacked him, immediately after receiving the wound, and the accussed’s admission
that he had applied a firebrand nto Aribuabo’s neck and had wounded him.
2. The extrajudicial confession of the accused, admitting that he inflicted the victim with a bamboo
spit in the same afternoon of the crime.
And despite the contention of the defense that the accused should not be convicted with homicide, but
only of serious physical injuries as the wound was not considered fatal and he may have survived it had
he not twice removed the drainage. According to Dr. Mendoza who examined Aribuabo, the wound
inflicted may occassionally result into traumatic peritonitis , and considered as a fatal consequence.
The element of the patient’s act in due to severe pain does not alter the judicial consequences of the
punishable act of the accussed.

One who inflicts an injury on another is deemed by the law to be guilty of homicide if the injury
contributes mediately or immediately to the death of such other. The fact that the other causes
contribute to the death does not relieve the actor of responsibility. . . . (13 R. C.L., 748.)

Furthermore, it is assumed that the patient had unconsciously removed the drainage due to pathological
condition and state of health brought by the severe pain that he was experiencing.

As the mitigating circumstances of lack of instruction and of intention to commit so grave a wrong as
that committed should be taken into consideration in favor of the appellant, without any aggravating
circumstances adverse to him. The appealed judgement was modified thru sentencing him to an
indeterminate penalty with a minimun of four years of prison correccional, and a maximum of eight
years of prision mayor, affirming it in all other respects, with costs to said Appellant.