GARCIA v.

People
Case Name
Amado Alvarado Garcia v. People of the Philippines
Topic Proximate Cause
Case No. |
171951 | 28 August 2009
Date
Ponente Quisumbing, J.
Case
Summary
Decision Motion for reconsideration denied
A person committing a felony is responsible for all the natural and logical consequences resulting
Doctrine from it although the unlawful act performed is different from the one he intended.

RELEVANT FACTS
• P was found guilty beyond reasonable doubt of homicide
 February 10, 2000: P was charged with murder
 September 29, 1999: P was armed with a bottle with intent to kill, attacked, boxed and clubbed
Manuel K. Chy inflicting fatal injuries causing his death.
 P pleaded not guilty
 September 26, P, Fidel Foz and Amando Foz were drinking in the apartment of Bogie Tacuboy,
which was beside the house of Manuel. At around 7 pm, Manuel asked the group to quiet down the
noise coming from videoke machine. P was heard threatening to hurt Manuel in Ilocano.
 September 28, group met to celebrate wedding of Ador Tacuboy. Maya Mabbun told them to stop
singing before they be told off again which further infuriated P.
 September 29, group met again and mulled over their drinking session. And P threatened to finish
Manuel off. That afternoon, group had another drinking session until P proposed they move to
Punta. On the way there, they passed by the store of Manuel’s sister and decided to have drinks there
instead.
 P ordered sister to call Manuel. Manuel approached P who punched him in the face, and continued
to assault him. P reached for beer bottle and struck Manuel’s head with it.
 Manuel escaped and asked wife to call the police. When the police came, there was no answer.
Minutes later manuel’s wife arrived and opened the door to find him on the floor salivating. He was
pronounced dead on arrival.
 Died of myocardial infection
 RTC: guilty beyond reasonable doubt for homicide. (10-14 years and 8 months imprisonment), pay
P50,000-Death indemnity, P200,000-Wake and burial, P300,000-Moral damages, P332,000-Loss of
earning
 Appeal December 20, 2005, affirmed conviction
 Motion for reconsideration denied
 RATIO DECIDENDI
Issue Ratio
Is the petitioner Yes
liable for Manuel
Chy’s death?  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.

RULING
WHEREFORE, appeal is DENIED for lack of merit. Decision of RTC is AFFIRMED
SEPARATE OPINION/S

NOTES