Urbano Vs - IAC

Filomeno Urbano vs. The Hon.
Intermediate Appellate Court

G.R. No. 72964, January 7, 1988
FACTS
Petitioner Filomeno Urbano went to his ricefield in Barangay Anonang, San Fabian, Pangasinan located
at about 100 meters from the tobacco seedbed of Marcelo Javier. He found the place where he stored
his palay flooded with water coming from the irrigation canal nearby which had overflowed. Urbano
saw Javier and Emilio Erfe cutting grass. He asked them who was responsible for the opening of the
irrigation canal and Javier admitted that he was the one. Urbano then got angry and demanded that
Javier pay for his soaked palay. A quarrel between them ensued. Urbano unsheathed his bolo and hacked
Javier hitting him on the right palm of his hand. Javier who was then unarmed ran away from Urbano
but was overtaken by Urbano who hacked him again hitting Javier on the left leg with the back portion
of said bolo, causing a swelling on said leg. When Urbano tried to hack and inflict further injury, his
daughter embraced and prevented him from hacking Javier. Javier was brought to Dr. Mario Meneses
for treatment since Dr. Guillermo Padilla, rural health physician, had no available medicine. After Javier
was treated by Dr. Meneses, he returned to Dr. Padilla who conducted a medico-legal examination.
Upon the intercession of Councilman Solis, Urbano and Javier agreed to settle their differences. Urbano
promised to pay P700.00 for the medical expenses of Javier. After about two weeks, Javier returned to
his farm and tended his tobacco plants. Thereafter, Javier was rushed to the Nazareth General Hospital
in a very serious condition. It was found that he had lockjaw and was having convulsions. Dr. Edmundo
Exconde, who personally attended to Javier, found that the latter was suffering from tetanus infection;
that the healing wound in Javier's palm could have been infected by tetanus. The next day, Javier died.
Filomeno Urbano was charged with the crime of homicide. The trial court found hin guilty as charged.
The then Intermediate Appellate Court (IAC) affirmed the conviction of Urbano on appeal but raised
the award of indemnity to the heirs of the deceased from P12,000 to P30,000.00 with costs against the
appellant.
ISSUES
1. Whether or not Javier's death was the natural and logical consequence of Urbano's unlawful act.
2. Whether or not Urbano can be fully exculpated from liability.
RULING
1. No, Javier's death was not the natural and logical consequence of Urbano's unlawful act.
The Supreme Court held as a matter of rule that the death of the victim must be the direct,
natural, and logical consequence of the wounds inflicted upon him by the accused. If an
independent negligent act or defective condition sets into operation the instances which result
in injury because of the prior defective condition, such subsequent act or condition is the
proximate cause. If the case is dealing with a criminal conviction, the proof that the accused
caused the victim’s death must convince a rational mind beyond reasonable doubt.
In the case under consideration, the medical findings show a distinct possibility that the
infection of the wound by tetanus was an efficient intervening cause later or between the time
Javier was wounded to the time of his death. The infection was, therefore, distinct and foreign
to the crime. There is a likelihood that the wound was but the remote cause and its subsequent
infection, for failure to take necessary precautions, with tetanus may have been the proximate
cause of Javier's death with which the petitioner had nothing to do. Javier's wound could have
been infected with tetanus after the hacking incident. However, the more credible conclusion is
that at the time Javier's wound was inflicted by the appellant, the severe form of tetanus that
killed him was not yet present. Considering the circumstance surrounding Javier's death, his
wound could have been infected by tetanus 2 or 3 or a few but not 20 to 22 days before he died.
Based from the foregoing, the petitioner's criminal liability in this respect was wiped out by the
victim's own act.
Thus, Javier's death was not the natural and logical consequence of Urbano's unlawful act.
2. No, Urbano cannot be fully exculpated from liability.
The well-settled doctrine is that a person, while not criminally liable, may still be civilly liable.
The law provides that while the guilt of the accused in a criminal prosecution must be
established beyond reasonable doubt, only a preponderance of evidence is required in a civil
action for damages. Further, jurisprudence holds that judgment of acquittal extinguishes the
civil liability of the accused only when it includes a declaration that the facts from which the
civil liability might arise did not exist.
Here, respondent court increased the P12,000.00 indemnification imposed by the trial court to
P30,000.00. However, since the indemnification was based solely on the finding of guilt beyond
reasonable doubt in the homicide case, the civil liability of the petitioner was not thoroughly
examined. This aspect of the case calls for fuller development if the heirs of the victim are so
minded.
The instant petition is granted.

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Filomeno Urbano vs. The Hon.

Intermediate Appellate Court

2. No, Urbano cannot be fully exculpated from liability.

The instant petition is granted.

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