People vs. Likiran

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PEOPLE OF THE PHILIPPINES vs.

JENNY LIKIRAN alias "Loloy"

G.R. No. 201858


Date: June 4, 2014

I. Ticker

Victim Sareno’s cause of death: 


Immediate cause : DOA 
Antecedent cause : Multiple gunshot wounds
Underlying cause : Stab wound scapular area (L)

II. Doctrine

Direct, natural and logical consequence

If a person inflicts a wound with a deadly weapon in such a manner as to


put life in jeopardy and death follows as a consequence of their felonious
act, it does not alter its nature or diminish its criminality to prove that
other causes cooperated in producing the factual result. The offender is
criminally liable for the death of the victim if his delictual act caused,
accelerated or contributed to the death of the victim. A different doctrine
would tend to give immunity to crime and to take away from human life a
salutary and essential safeguard. 

III. Facts

 While Mercado and Goloceno were inside the dance area, Jerome
Likiran3 (Jerome), the accused-appellant’s brother, punched Mercado on
the mouth. Goloceno was about to assist Mercado when he saw that
Jerome was armed with a short firearm while the accused-appellant was
holding a hunting knife, so he backed off.
 Dagangon and Sareno, who were outside the dance area, heard the
commotion. Afterwards, Jerome approached Sareno and shot him
several times. With Sareno fallen, the accused-appellant stabbed him on
the back. It was Dagangon who saw the incident first-hand as he was
only three meters from where Sareno was. Dagangon was able to bring
Sareno to the hospital only after Jerome and the accused-appellant left,
but Sareno was already dead at that point. Sareno suffered multiple
gunshot wounds and a stab wound at the left scapular area. 4
 The accused-appellant denied any involvement in the crime. While he
admitted that he was at the dance, he did not go outside when the
commotion happened. He and Jerome stayed within the area where the
sound machine was located and they only heard the gunshots outside.
Other witnesses testified in the accused-appellant’s defense, with Edgar
Indanon testifying that he saw the stabbing incident and that it was some
other unknown person, and not the accused-appellant, who was the
culprit; and Eleuterio Quiñopa stating that he was with the accused-
appellant and Jerome inside the dance hall at the time the commotion
occurred.
 Prosecution witness Dagangon’s positive identification of the accused-
appellant was held sufficient by the RTC to convict the latter of the crime
of murder.6 The RTC also rejected the accused-appellant’s defense of
denial as it was not supported by evidence. It also ruled that alibi cannot
favor the accused-appellant since he failed to prove that it was
impossible for him to be at the scene of the crime on the night of March
19, 2000.7
 The accused-appellant also asserted that the information charged him of
murder committed by attacking, assaulting, stabbing and shooting
Sareno, thereby causing his instantaneous death.
 The pre-trial agreement issued by the RTC states that the Certificate of
Death issued by Dr. Cidric Dael (Dr. Dael) of the Bukidnon Provincial
Hospital and reviewed by the Rural Health Physician of Malaybalay City
"is admitted as proof of fact and cause of death due to multiple stab
wound scapular area."24
 The accused-appellant is criminally liable for the natural and logical
consequence resulting from his act of stabbing Sareno. It may be that he
was not the shooter but the stab wound he inflicted on Sareno
contributed to the latter’s death. 
 RTC GUILTY,CA AFFIRMED.

IV. Issues

Whether or not death of Sereno is the natural and logical consequence


resulting from the act of Likiran.

V. Decision/Ruling

YES.

More importantly, the accused-appellant is criminally liable for the natural


and logical consequence resulting from his act of stabbing Sareno. It
may be that he was not the shooter, it is nevertheless true that the stab
wound he inflicted on Sareno contributed to the latter’s death. In Quinto
v. Andres,30 the Court stated that:

If a person inflicts a wound with a deadly weapon in such a manner as to


put life in jeopardy and death follows as a consequence of their felonious
act, it does not alter its nature or diminish its criminality to prove that
other causes cooperated in producing the factual result. The offender is
criminally liable for the death of the victim if his delictual act caused,
accelerated or contributed to the death of the victim. A different doctrine
would tend to give immunity to crime and to take away from human life a
salutary and essential safeguard. x x x[.]31 (Citations omitted and
emphasis ours)

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