Alvarado Garcia v People of the Philippines

GR No. 171951

Doctrine: A person committing a felony is responsible for all the natural and logical
consequences resulting from it although the unlawful act performed is different from the one
he intended.

FACTS:

Amado Garcia and Fidel Foz Jr., had a drinking spree in the morning of September 1999 that
lasted the until the evening of that day. Because of the blaring noise of the videoke machine
that the two were enjoying, Manuel Chy, told the group to quiet down. Two days after, the met
again on a wedding and again, Chy told the two to stop singing. On the next day, the two, now
with a friend, decided to have a drinking session and later moved to Punta.

On their way to Punta, they saw Chy. The petitioner suddenly assaulted Chy and struck him on
the lower part of his head with a bottle. When Chy found a way to escape, he rushed to his
home and phoned his wife and told her to call the police. When they arrived, they found Chy
unconcsious and later pronounced dead on arrival at the hospital

The petitioner was found guilty beyond reasonable doubt of homicide. The petitioner
contended that he should only be charged with slight physical injuries as his assault on Chy was
not he cause of his death.

ISSUE:

Whether or not Garcia is liable for Manuel Chy’s death

RULING:

Yes. It can be reasonably inferred from the foregoing statements that the emotional strain from
the beating aggravated Chy’s delicate constitution and led to his death. The inevitable
conclusion then surfaces that the myocardial infarction suffered by the victim was the direct,
natural and logical consequence of the felony that petitioner had intended to commit.

The essential requisites for the application of this Article 4 of the RPC are:

(a) the intended act is felonious;

(b) the resulting act is likewise a felony; and
(c) the unintended albeit graver wrong was primarily caused by the actor’s wrongful acts.
Hence, the fact that Chy was previously afflicted with a heart ailment does not alter petitioner’s
liability for his death. a person committing a felony is responsible for all the natural and logical
consequences resulting from it although the unlawful act performed is different from the one
he intended.