“Sometimes an aggressor does not intend the serious consequences of his acts.”
Sometimes an aggressor does not intend the serious consequences of his acts. However, if a person commits a felony, “[he or she] is criminally liable for all the natural and logical consequences resulting therefrom unless there was an efficient intervening active force that intervened between the felony committed and the resulting injury” (G.R. No. 250895, June 16, 2021).
In the case of People v. Lalap, “[w]hile Honorio was eating, Mario Lalap entered the house through the kitchen’s door and immediately stabbed Honorio from behind. Honorio stood up but Mario tried to pull the former outside of [the] house [and] [a]fter failing to pull him outside[,] Mario stabbed Honorio for the second time…” (G.R. No. 250895, June 16, 2021)
“While Honorio was being stabbed, Mario shouted at Honorio saying ‘… papatayin kita. Tsismoso ka.’ Joy [daughter of Honorio] begged Mario to stop by shouting ‘Tama na po’ but Mario ignored her plea” (G.R. No. 250895, June 16, 2021).
“The accused learned from his wife, after the latter monitored the condition of Honorio… that he was getting better and was about to be discharged from the hospital. However, Honorio suddenly suffered a cardiac arrest and died [consequently].”
“[Mario] argues that the CA and the RTC overlooked the fact that the stab wound allegedly sustained by the victim was not the immediate and direct cause of his death. He maintains that based on the records, the immediate cause of the victim’s death which occurred nine days after the stabbing incident is cardiorespiratory arrest.”
“The case of Quinto v. Andres, explained ‘that a person committing a felony is criminally liable for all the natural and logical consequences resulting therefrom unless there was an efficient intervening active force that intervened between the felony committed and the resulting injury… although the wrongful act done be different from that which he intended’” (cited in People v. Lalap, G.R. No. 250895, June 16, 2021).
“‘Natural’ refers to an occurrence in the ordinary course of human life or events, while ‘logical’ means that there is a rational connection between the act of the accused and the resulting injury or damage. The felony committed must be the proximate cause of the resulting injury” (G.R. No. 250895, June 16, 2021).
“Proximate cause is that cause which in natural and continuous sequence, unbroken by an efficient intervening cause, produces the injury, and without which the result would not have occurred.” “There must be a relation of ‘cause and effect,’ the cause being the felonious act of the offender, the effect being the resultant injuries and/or death of the victim” (G.R. No. 250895, June 16, 2021).
“The ‘cause and effect’ relationship is not altered or changed [by] pre-existing conditions, such as the pathological condition of the victim…, the predisposition of the offended party…, [and] the physical condition of the offended party…; [as well as] concomitant or concurrent conditions, such as the negligence or fault of the doctors… or the conditions supervening the felonious act such as tetanus, pulmonary infection or gangrene” (G.R. No. 250895, June 16, 2021).
“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” (G.R. No. 250895, June 16, 2021).
“While the immediate cause of the victim’s death as reflected in the Medical Certificate is cardiorespiratory arrest, the stab wound that [Honorio] inflicted on the vital part of the victim’s body is the proximate cause of the victim’s death. The stab wound is the cause which in the natural and continuous sequence, unbroken by an efficient intervening cause, produces the victim’s death, and without which the result would not have occurred.”
“Logically, there is a rational connection between the act of [Honorio] stabbing the victim and the resulting death. Without the stab wound, the victim could not have been hospitalized and later died therefrom.”
“Moreover, there is no evidence that an efficient intervening active force, not connected with or absolutely foreign to the stab wound, intervened during the nine-day period which could have caused the victim’s death. Thus, even if there was another factor but such is not an efficient intervening cause, [Honorio] is still criminally liable for the death of the victim…”
“[E]ven [if] for argument’s sake… the victim was previously suffering a disease or ailment, accused-appellant is still liable because his act of stabbing the victim hastened or accelerated the victim’s death. Thus, in Garcia v. People the Court said:
x x x [A]lthough the assaulted party was previously affected by some internal malady, if, because of a blow given with the hand or the foot, his death was hastened, beyond peradventure he is responsible therefor who produced the cause for such acceleration as the result of a voluntary and unlawfully inflicted injury.” (cited in G.R. No. 250895, June 16, 2021)
