People vs.

UlepFacts: Macario Ulep, accused, elbowed her wife on her breast, upon
being drunk and utteringindecent words. Subsequently, the victi vo ited and then went
to bed. !he accused then leftfor the fields and upon returning ho e, found his wife dead. "e
i ediately reported this deathto their barrio captain. Medical reports show that the
victi #s cause of death is due to cardiacarrest and pri ary shock.$ssue: %&' the accused
is cri inally liable for the death of his wife."eld: (es. )ven though a blow with the fist or a kick
does not cause any e*ternal wound, it ay easily produce infla ation of the spleen and
peritonitis and cause death, and even though the victi ay have been previously affected by
so e internal alady, yet if the blow with the fistor foot accelerated death, he who
caused such acceleration is responsible for the death as theresult of an in+ury willfully
and unlawfully inflicted.!here is that clear and categorical showing that on the
appellant fell the bla e for these inhu an acts on his wife. "e should answer for her tragic
death.!hough, the appellant presented a witness to prove that so eti e,his wife was pinned
down by a sack of rice and the side portion of a bullcart and was attended to by a
town quack doctorcalled an
arbularyo
. !his witness said that two - ribs on each side of the chest were
fractured, without stating which particular ribs were so affected. "owever, it was being held tha
t even if the victi is suffering fro an internal ail ent, liver or heart disease, or
tuberculosis, if the blow delivered by the accused / a is the efficient cause of death0 or b
accelerated his death0 or c is the pro*i ate cause of death0 then there is cri inal
liability. 1propos to all these is that ti e2respected doctrine: 3"e who is the cause of the cause i
s thec a u s e o f t h e e v i l c a u s e d . 3 ! h i s i s t h e r a t i o n a l e i n 1 r t i c l e 4 o f t h e
5evised Penal 6ode whichprovides that 3cri inal liability shall be
i n c u r r e d b y a p e r s o n c o i t t i n g a f e l o n y d e l i t o although the wrongful act done
be different fro that which he intended.3