University of the Philippines College of Law

CJSE D2021

Case Name PP vs Iligan

Case No. | Date G.R. No. 75369. November 26, 1990
Ponente Fernan, ​J.
At around 2 in the morning Esmeraldo Quinones and his companions Zaldy Asis and Felix
Lukban were walking home from barangay Sto. Domingo after attending a barrio fiesta. On the
way they met the accused Fernando Iligan and his nephew Edmundo Asis and Juan Macandog.
Edmundo Asis pushed them aside prompting Zaldy Asis to box him. Felix quickly said that they
had no desire to fight. Upon seeing his nephew fall, Fernando Iligan drew from his back a bolo
and hacked Zaldy but missed. Terrified the trio ran, pursued by the three accused. They ran for
Case Summary a good while and even passed the house of Quinones, when they noticed that they were no
longer being chased the three decided to head back to Quinones house. On the way back the
three accused suddenly emerged from the road side, Fernando Iligan then hacked Quinones Jr.
on the forehead with his bolo causing him to fall down. Felix and Zaldy ran. Upon returning they
saw that Quinones Jr. was already dead with his head busted. The postmortem examination
report and the death certificate indicates that the victim died of “ shock and massive cerebral
hemorrhages due to ​vehicular accident​.”
Article 4, Par. 1 of the RPC:
“Criminal liability shall be incurred:
Doctrine
● By any person committing a felony although the wrongful act done be different from
that which he intended”

Issue
W/N the accused are
liable for the victim’s
death given that it
was due to a vehicular
accident and not the
hacking.
RATIO DECIDENDI
Ratio
YES. We are convinced beyond peradventure that indeed after Quinones, Jr. had fallen
from the bolo hacking perpetrated by Iligan, he was run over by a vehicle. This finding,
however, does not in any way exonerate Iligan from liability for the death of Quinones Jr.
This being under ART 4 of the RPC which states that criminal liability shall be incurred by
any person committing a felony although the wrongful act done be different from that
which he intended.
The essential requisites of Art 4 are:
● that an intentional felony has been committed and that the wrong done to the
aggrieved party be the direct natural and logical consequence of the felony
committed by the offender.
It is held that the essential elements are present in this case. The intentional felony
committed was the hacking of the head of Quinones the fact that it was considered
superficial by the physician is immaterial. The location of the wound intended to do
away with him.
The hacking incident happened on the national highway where vehicles pass any
moment, the hacking blow received by Quinones weakened him and was run over by a
vehicle. The hacking by Iligan is thus deemed as the proximate cause of the victim’s
death.
 University of the Philippines College of Law
CJSE D2021
RULING
WHEREFORE​, appellant Fernando Iligan y Jamito is hereby ​convicted​ of the crime of homicide for which he is
imposed the indeterminate penalty of six (6) years and one (1) day of prision mayor as minimum to fourteen (14)
years, eight (8) months and one (1) day of reclusion temporal medium as maximum and he shall indemnify the heirs
of Esmeraldo Quiñones, Jr. in the amount of fifty thousand pesos (P50,000). Appellant Edmundo Asis is hereby
acquitted of the crime charged against him. Costs against appellant Iligan.

SEPARATE OPINIONS

NOTES