Prepared by : Alexander B.

Olila / 071915

Case : People v. Cornel, 78 Phil. 458, G.R. No. L-204, May 16, 1947,

Ponente : Paras, J.

Doctrine : Revised Penal Code Art. 4.1. Criminal liability shall be incurred by a person
committing a felony (delito) although the wrongful act done be different form
that which he intended.

Facts : The appellant, who was initially prosecuted for physical injuries prior to the
death of the Fabian Burac, was eventually convicted for the crime of homicide
by the judgment of the Court of First Instance of Albay.

The appeal was based on two arguments. Firstly, the alleged inadequacy of
evidence for the prosecution to establish the appellant’s identity and secondly,
that the cause of death of the victim is possibly because of other diseases which
may exhibit tetanus-like symptoms. The identity of the assailant was established
through testimonies of the victim’s wife and mother-in-law which the court
accepted to be truthful. The victim survived the initial injuries sustained from a
bolo hacked to the forehead and stone struck thereafter to the right clavicle
caused by the appellant. However, the victim eventually died of tetanus few
days after because it was not available at the time.

Issue/s : Is the defendant still liable for the death of the victim when the cause of death
is a direct, natural and logical consequence of the committed felony?

Is the criminal intent justified by the appellant’s motive to cause injury to the
deceased victim of crime (homicide)?

Held : The Supreme Court ruled that the appellant’s defense of alibi of not being
present during the time of the incident would have been worth investigating if
the wife was not an eyewitness to the criminal offense. They added that the
victim certainly died of tetanus as a complication of the felony committed by the
appellant. Because of this, the appellant must be held liable for the natural
consequences of his unlawful act. Furthermore, the motive for the offense was
determined by the circumstance that the deceased victim once arrested and
threatened the appellant during the Japanese occupation.