People v. Acuram

Download as docx, pdf, or txt
Download as docx, pdf, or txt
You are on page 1of 2

47. PEOPLE V. ACURAM - G.R. No.

117954 (April 27, 2000)


Facts: On June 29, 1991, at about 7:00 o'clock in the evening, Manabat and his companions went to the
market to buy fish. Since no fish was available at that time, they decided to go home instead. They went to
the national highway, stood at the right side and waited for a ride there. They flagged down an
approaching passenger jeepney which, however, swerved dangerously towards them. At this juncture,
Manabat shouted at the jeep "Pesteng yawa-a kamo, Manligis man kamo" (You devils, why did you try to
run over us?). A passenger inside the jeepney shouted back "Noano man diay, isog mo?" (Why? Are you
brave?). Immediately thereafter, two gunshots rang out in the air, accompanied by sparks coming from the
front right side of the jeepney. Then Manabat shouted, "Agay. I was shot." The vehicle did not stop but
instead speeded towards the direction of Cagayan de Oro City.
Wounded on the right knee, Rolando was brought by his companions to the Cagayan de Oro
Medical Center. Later on, they were informed that Rolando needed blood transfusion and so they
transferred him at around 11:25 P.M. to the Northern Mindanao Regional Hospital in the same city. Upon
arrival at the hospital, Manabat’s BP was found to be just over zero (40/0) and the victim's right leg was
heavily bandaged. He was operated when the BP stabilized but still died the next day.
The doctor testified that the death was due to massive loss of blood due to gunshot wound. The
doctor stated that under normal circumstances, the wound would not necessarily cause death but in this
case where the wound transected the major part of the leg, the wound was fatal. He clarified that the
victim sustained only one gunshot wound which entered at the front portion of the right knee and exited
at the back of the right knee, causing two wounds.
Upon investigation, It was discovered that Orlando was a policeman who was among the
passengers of the errant jeepney. He was seated at the front, right side of the jeepney and was the only
one among its passengers who was carrying a firearm. He later on surrendered and when charged entered
a plea of not guilty.
During the trial, he admitted that he was on board the mentioned jeepney and had a gun at that
time but denied firing it. He claimed that it was impossible for him to fire his rifle during that time since he
was sitting at the front seat of the jeepney, sandwiched between the driver and the latter's father-in-law.
Moreover, he said that the rifle was locked and wrapped by his jacket and its barrel was even pointed
towards the driver.
Orlando also, in his attempt to exculpate himself, blames the death of the victim on the lack of
prompt and proper medical attention given. He insists that the delay in giving proper medical attendance
to the victim constitutes an efficient intervening cause which exempts him from criminal responsibility.

Issue: W/N the doctors can be held liable for the death of the victim Manabat?
Ruling: No. We cannot hold the attending doctors liable for the death of the victim. The perceived delay in
giving medical treatment to the victim does not break at all the causal connection between the wrongful
act of the appellant and the injuries sustained by the victim. It does not constitute efficient intervening
cause.

The proximate cause of the death of the deceased is the shooting by Orlando. It is settled that anyone
inflicting injuries is responsible for all the consequences of his criminal act such as death that supervenes in
consequence of the injuries. The fact that the injured did not receive proper medical attendance would not
affect Orlando's criminal responsibility. The rule is founded on the practical policy of closing to the
wrongdoer a convenient avenue of escape from the just consequences of his wrongful act. If the rule were
otherwise, many criminals could avoid just accounting for their acts by merely establishing a doubt as to
the immediate cause of death.

You might also like